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Maurice William "Bill" Campbell Jr., 59, is accused of using his former position as director of the Alabama Small Business Development Consortium to obtain about $7.3 million from the state, prosecutors said. The organization, composed of four-year universities, is supposed to provide businesses with assistance for economic development, training and management.
Citation preview
JWVTMJGAM March 2011DTF GJ 8
IN THE UNITED STATES DISTRICT COURT FOR THENORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION
UNITED STATES OF AMERICA
v CR -
MAURICE WILLIAM CAMPBELL JR SUPERSEDINGalso known as BILL CAMPBELL also known as ldquoSIR WILLIAMrdquo
Defendant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (ldquothe Consortiumrdquo or ldquoASBDCrdquo) The Consortium was
comprised of four-year institutions in the State of Alabama ndash each of which had its
own small business development center ndash as well as a procurement technical center
and an international trade center The ASBDCrsquos purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 1 of 41
businesses and to develop Alabamarsquos workforce The State Directorrsquos office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit of any
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501(c)(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutersquos stated purposes
Count OneMail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ldquoASBDCrdquo) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a ldquoProject
Questionnairerdquo
5 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause a ldquoProject Questionnairerdquo to be completed and sent to private
counsel administering bond proceeds for the State The ldquoProject Questionnairerdquo
identified the project for which State money was requested as the ldquoJacksonville
4
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 4 of 41
State University Small Business Development Consortiumrdquo In the questionnaire
the ldquoproject ownerrdquo was identified as the ldquoAlabama Small Business Development
Consortiumrdquo In the ldquoUse of the Projectrdquo section the question stated ldquoOther than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any lsquopersonrsquo (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide detailsrdquo The
typed answer stated ldquoIt will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University of North Alabama
Alabama AampM University University of Alabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabamardquo
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about May 31 2005 did cause
to be sent by facsimile to the Department of Finance documents concerning the
ASBDC request for funding including a ldquoTotal Program Cost Worksheetrdquo stating
the ldquocost to run the ASBDC Program for 2 yearsrdquo
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 2 2005 did cause to
be mailed from the State Department of Finance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of $150000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 15 2005 as
President of the Alabama Small Business Institute of Commerce (ldquoThe Instituterdquo)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 1 2005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 4 2005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $100000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name of The Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailing
14 On or about June 2 2005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count TwoConspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the Stateof Alabama and the private nonprofit Institute and to obtain money andproperty belonging to others by means of false and fraudulent pretensesrepresentations and promises by use of United States mail or interstatecarrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud theState of Alabama and the private nonprofit Institute and to obtainmoney and property belonging to others by means of false andfraudulent pretenses representations and promises by use of interstatewire transmissions in violation of Title 18 United States CodeSection 1343
(C) to conduct or attempt to conduct a financial transaction which in factinvolves the proceeds of specified unlawful activity with the intent topromote the carrying on of specified unlawful activity or with intent toengage in conduct constituting a violation of section 7201 or 7206 of theInternal Revenue Code of 1986 or knowing that the transaction is designedin whole or in part to conceal or disguise the nature the location the sourcethe ownership or the control of the proceeds of specified unlawful activityor to avoid a transaction reporting requirement under State or Federal law inviolation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminallyderived property of a value greater than $10000 and that is derived fromspecified unlawful activity in violation of Title 18 United States CodeSection 1957
9
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials ndash including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
businesses and to develop Alabamarsquos workforce The State Directorrsquos office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit of any
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501(c)(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutersquos stated purposes
Count OneMail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ldquoASBDCrdquo) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a ldquoProject
Questionnairerdquo
5 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause a ldquoProject Questionnairerdquo to be completed and sent to private
counsel administering bond proceeds for the State The ldquoProject Questionnairerdquo
identified the project for which State money was requested as the ldquoJacksonville
4
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 4 of 41
State University Small Business Development Consortiumrdquo In the questionnaire
the ldquoproject ownerrdquo was identified as the ldquoAlabama Small Business Development
Consortiumrdquo In the ldquoUse of the Projectrdquo section the question stated ldquoOther than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any lsquopersonrsquo (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide detailsrdquo The
typed answer stated ldquoIt will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University of North Alabama
Alabama AampM University University of Alabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabamardquo
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about May 31 2005 did cause
to be sent by facsimile to the Department of Finance documents concerning the
ASBDC request for funding including a ldquoTotal Program Cost Worksheetrdquo stating
the ldquocost to run the ASBDC Program for 2 yearsrdquo
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 2 2005 did cause to
be mailed from the State Department of Finance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of $150000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 15 2005 as
President of the Alabama Small Business Institute of Commerce (ldquoThe Instituterdquo)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 1 2005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 4 2005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $100000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name of The Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailing
14 On or about June 2 2005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count TwoConspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the Stateof Alabama and the private nonprofit Institute and to obtain money andproperty belonging to others by means of false and fraudulent pretensesrepresentations and promises by use of United States mail or interstatecarrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud theState of Alabama and the private nonprofit Institute and to obtainmoney and property belonging to others by means of false andfraudulent pretenses representations and promises by use of interstatewire transmissions in violation of Title 18 United States CodeSection 1343
(C) to conduct or attempt to conduct a financial transaction which in factinvolves the proceeds of specified unlawful activity with the intent topromote the carrying on of specified unlawful activity or with intent toengage in conduct constituting a violation of section 7201 or 7206 of theInternal Revenue Code of 1986 or knowing that the transaction is designedin whole or in part to conceal or disguise the nature the location the sourcethe ownership or the control of the proceeds of specified unlawful activityor to avoid a transaction reporting requirement under State or Federal law inviolation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminallyderived property of a value greater than $10000 and that is derived fromspecified unlawful activity in violation of Title 18 United States CodeSection 1957
9
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials ndash including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutersquos stated purposes
Count OneMail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ldquoASBDCrdquo) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a ldquoProject
Questionnairerdquo
5 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause a ldquoProject Questionnairerdquo to be completed and sent to private
counsel administering bond proceeds for the State The ldquoProject Questionnairerdquo
identified the project for which State money was requested as the ldquoJacksonville
4
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 4 of 41
State University Small Business Development Consortiumrdquo In the questionnaire
the ldquoproject ownerrdquo was identified as the ldquoAlabama Small Business Development
Consortiumrdquo In the ldquoUse of the Projectrdquo section the question stated ldquoOther than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any lsquopersonrsquo (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide detailsrdquo The
typed answer stated ldquoIt will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University of North Alabama
Alabama AampM University University of Alabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabamardquo
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about May 31 2005 did cause
to be sent by facsimile to the Department of Finance documents concerning the
ASBDC request for funding including a ldquoTotal Program Cost Worksheetrdquo stating
the ldquocost to run the ASBDC Program for 2 yearsrdquo
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 2 2005 did cause to
be mailed from the State Department of Finance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of $150000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 15 2005 as
President of the Alabama Small Business Institute of Commerce (ldquoThe Instituterdquo)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 1 2005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 4 2005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $100000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name of The Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailing
14 On or about June 2 2005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count TwoConspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the Stateof Alabama and the private nonprofit Institute and to obtain money andproperty belonging to others by means of false and fraudulent pretensesrepresentations and promises by use of United States mail or interstatecarrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud theState of Alabama and the private nonprofit Institute and to obtainmoney and property belonging to others by means of false andfraudulent pretenses representations and promises by use of interstatewire transmissions in violation of Title 18 United States CodeSection 1343
(C) to conduct or attempt to conduct a financial transaction which in factinvolves the proceeds of specified unlawful activity with the intent topromote the carrying on of specified unlawful activity or with intent toengage in conduct constituting a violation of section 7201 or 7206 of theInternal Revenue Code of 1986 or knowing that the transaction is designedin whole or in part to conceal or disguise the nature the location the sourcethe ownership or the control of the proceeds of specified unlawful activityor to avoid a transaction reporting requirement under State or Federal law inviolation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminallyderived property of a value greater than $10000 and that is derived fromspecified unlawful activity in violation of Title 18 United States CodeSection 1957
9
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials ndash including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 15 of 41
30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ldquoASBDCrdquo) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a ldquoProject
Questionnairerdquo
5 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause a ldquoProject Questionnairerdquo to be completed and sent to private
counsel administering bond proceeds for the State The ldquoProject Questionnairerdquo
identified the project for which State money was requested as the ldquoJacksonville
4
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 4 of 41
State University Small Business Development Consortiumrdquo In the questionnaire
the ldquoproject ownerrdquo was identified as the ldquoAlabama Small Business Development
Consortiumrdquo In the ldquoUse of the Projectrdquo section the question stated ldquoOther than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any lsquopersonrsquo (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide detailsrdquo The
typed answer stated ldquoIt will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University of North Alabama
Alabama AampM University University of Alabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabamardquo
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about May 31 2005 did cause
to be sent by facsimile to the Department of Finance documents concerning the
ASBDC request for funding including a ldquoTotal Program Cost Worksheetrdquo stating
the ldquocost to run the ASBDC Program for 2 yearsrdquo
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 2 2005 did cause to
be mailed from the State Department of Finance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of $150000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 15 2005 as
President of the Alabama Small Business Institute of Commerce (ldquoThe Instituterdquo)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 1 2005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 4 2005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $100000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name of The Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailing
14 On or about June 2 2005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count TwoConspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the Stateof Alabama and the private nonprofit Institute and to obtain money andproperty belonging to others by means of false and fraudulent pretensesrepresentations and promises by use of United States mail or interstatecarrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud theState of Alabama and the private nonprofit Institute and to obtainmoney and property belonging to others by means of false andfraudulent pretenses representations and promises by use of interstatewire transmissions in violation of Title 18 United States CodeSection 1343
(C) to conduct or attempt to conduct a financial transaction which in factinvolves the proceeds of specified unlawful activity with the intent topromote the carrying on of specified unlawful activity or with intent toengage in conduct constituting a violation of section 7201 or 7206 of theInternal Revenue Code of 1986 or knowing that the transaction is designedin whole or in part to conceal or disguise the nature the location the sourcethe ownership or the control of the proceeds of specified unlawful activityor to avoid a transaction reporting requirement under State or Federal law inviolation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminallyderived property of a value greater than $10000 and that is derived fromspecified unlawful activity in violation of Title 18 United States CodeSection 1957
9
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials ndash including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
State University Small Business Development Consortiumrdquo In the questionnaire
the ldquoproject ownerrdquo was identified as the ldquoAlabama Small Business Development
Consortiumrdquo In the ldquoUse of the Projectrdquo section the question stated ldquoOther than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any lsquopersonrsquo (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide detailsrdquo The
typed answer stated ldquoIt will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University of North Alabama
Alabama AampM University University of Alabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabamardquo
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about May 31 2005 did cause
to be sent by facsimile to the Department of Finance documents concerning the
ASBDC request for funding including a ldquoTotal Program Cost Worksheetrdquo stating
the ldquocost to run the ASBDC Program for 2 yearsrdquo
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 2 2005 did cause to
be mailed from the State Department of Finance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of $150000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 15 2005 as
President of the Alabama Small Business Institute of Commerce (ldquoThe Instituterdquo)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 1 2005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 4 2005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $100000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name of The Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailing
14 On or about June 2 2005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count TwoConspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the Stateof Alabama and the private nonprofit Institute and to obtain money andproperty belonging to others by means of false and fraudulent pretensesrepresentations and promises by use of United States mail or interstatecarrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud theState of Alabama and the private nonprofit Institute and to obtainmoney and property belonging to others by means of false andfraudulent pretenses representations and promises by use of interstatewire transmissions in violation of Title 18 United States CodeSection 1343
(C) to conduct or attempt to conduct a financial transaction which in factinvolves the proceeds of specified unlawful activity with the intent topromote the carrying on of specified unlawful activity or with intent toengage in conduct constituting a violation of section 7201 or 7206 of theInternal Revenue Code of 1986 or knowing that the transaction is designedin whole or in part to conceal or disguise the nature the location the sourcethe ownership or the control of the proceeds of specified unlawful activityor to avoid a transaction reporting requirement under State or Federal law inviolation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminallyderived property of a value greater than $10000 and that is derived fromspecified unlawful activity in violation of Title 18 United States CodeSection 1957
9
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials ndash including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
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COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
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50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about May 31 2005 did cause
to be sent by facsimile to the Department of Finance documents concerning the
ASBDC request for funding including a ldquoTotal Program Cost Worksheetrdquo stating
the ldquocost to run the ASBDC Program for 2 yearsrdquo
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 2 2005 did cause to
be mailed from the State Department of Finance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of $150000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 15 2005 as
President of the Alabama Small Business Institute of Commerce (ldquoThe Instituterdquo)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 1 2005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 4 2005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $100000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name of The Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailing
14 On or about June 2 2005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count TwoConspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the Stateof Alabama and the private nonprofit Institute and to obtain money andproperty belonging to others by means of false and fraudulent pretensesrepresentations and promises by use of United States mail or interstatecarrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud theState of Alabama and the private nonprofit Institute and to obtainmoney and property belonging to others by means of false andfraudulent pretenses representations and promises by use of interstatewire transmissions in violation of Title 18 United States CodeSection 1343
(C) to conduct or attempt to conduct a financial transaction which in factinvolves the proceeds of specified unlawful activity with the intent topromote the carrying on of specified unlawful activity or with intent toengage in conduct constituting a violation of section 7201 or 7206 of theInternal Revenue Code of 1986 or knowing that the transaction is designedin whole or in part to conceal or disguise the nature the location the sourcethe ownership or the control of the proceeds of specified unlawful activityor to avoid a transaction reporting requirement under State or Federal law inviolation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminallyderived property of a value greater than $10000 and that is derived fromspecified unlawful activity in violation of Title 18 United States CodeSection 1957
9
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials ndash including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
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THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
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Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
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Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
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70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
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Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
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NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
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NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
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(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 1 2005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 4 2005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $100000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name of The Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailing
14 On or about June 2 2005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count TwoConspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the Stateof Alabama and the private nonprofit Institute and to obtain money andproperty belonging to others by means of false and fraudulent pretensesrepresentations and promises by use of United States mail or interstatecarrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud theState of Alabama and the private nonprofit Institute and to obtainmoney and property belonging to others by means of false andfraudulent pretenses representations and promises by use of interstatewire transmissions in violation of Title 18 United States CodeSection 1343
(C) to conduct or attempt to conduct a financial transaction which in factinvolves the proceeds of specified unlawful activity with the intent topromote the carrying on of specified unlawful activity or with intent toengage in conduct constituting a violation of section 7201 or 7206 of theInternal Revenue Code of 1986 or knowing that the transaction is designedin whole or in part to conceal or disguise the nature the location the sourcethe ownership or the control of the proceeds of specified unlawful activityor to avoid a transaction reporting requirement under State or Federal law inviolation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminallyderived property of a value greater than $10000 and that is derived fromspecified unlawful activity in violation of Title 18 United States CodeSection 1957
9
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials ndash including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
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Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
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NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
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NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
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(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count TwoConspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the Stateof Alabama and the private nonprofit Institute and to obtain money andproperty belonging to others by means of false and fraudulent pretensesrepresentations and promises by use of United States mail or interstatecarrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud theState of Alabama and the private nonprofit Institute and to obtainmoney and property belonging to others by means of false andfraudulent pretenses representations and promises by use of interstatewire transmissions in violation of Title 18 United States CodeSection 1343
(C) to conduct or attempt to conduct a financial transaction which in factinvolves the proceeds of specified unlawful activity with the intent topromote the carrying on of specified unlawful activity or with intent toengage in conduct constituting a violation of section 7201 or 7206 of theInternal Revenue Code of 1986 or knowing that the transaction is designedin whole or in part to conceal or disguise the nature the location the sourcethe ownership or the control of the proceeds of specified unlawful activityor to avoid a transaction reporting requirement under State or Federal law inviolation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminallyderived property of a value greater than $10000 and that is derived fromspecified unlawful activity in violation of Title 18 United States CodeSection 1957
9
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials ndash including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the Stateof Alabama and the private nonprofit Institute and to obtain money andproperty belonging to others by means of false and fraudulent pretensesrepresentations and promises by use of United States mail or interstatecarrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud theState of Alabama and the private nonprofit Institute and to obtainmoney and property belonging to others by means of false andfraudulent pretenses representations and promises by use of interstatewire transmissions in violation of Title 18 United States CodeSection 1343
(C) to conduct or attempt to conduct a financial transaction which in factinvolves the proceeds of specified unlawful activity with the intent topromote the carrying on of specified unlawful activity or with intent toengage in conduct constituting a violation of section 7201 or 7206 of theInternal Revenue Code of 1986 or knowing that the transaction is designedin whole or in part to conceal or disguise the nature the location the sourcethe ownership or the control of the proceeds of specified unlawful activityor to avoid a transaction reporting requirement under State or Federal law inviolation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminallyderived property of a value greater than $10000 and that is derived fromspecified unlawful activity in violation of Title 18 United States CodeSection 1957
9
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials ndash including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
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WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
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officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
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5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials ndash including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
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NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
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NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
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(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the ldquoLittle Sistersrdquo and to make purchases for the ldquoLittle Sistersrdquo
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name of Baptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the ldquoLittle Sistersrdquo
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
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50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (ldquothe Instituterdquo or ldquoASBICrdquo)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the ldquoOperating Accountrdquo (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 15 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $120000000
27 On or about August 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the ldquoTravel
Accountrdquo (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 15 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
30 On or about October 1 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 1 2006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 11 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for ldquoJan Feb March April amp May Rentrdquo to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 738 in the
amount of $1500000 for ldquoOct Nov amp Dec Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 17 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
amount of $1500000 for ldquoJune July August Rentrdquo to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
39 On or about September 12 2007 and on a monthly basis for the
remainder of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 1 2007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 23 2007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 18 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
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WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
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WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
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officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
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5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
of 2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of $193099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (x1459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 1 2008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
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Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
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Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
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70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
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Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
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NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
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omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
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NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
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(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 9 2008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the ldquoLittle Sistersrdquo and treated
them to dinner at Bottega which was paid for on the Bookkeeperrsquos Institute
checkcard in the amount of $71565
49 On or about January 15 2009 and on a monthly basis for the remainder
of 2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 20 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
the amount of $154440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words ldquoSir
Williamrdquo and ldquoLil Sisterrdquo
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf of Baptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide ldquomarketing servicesrdquo to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee of Regency Pointe to open an account at
Regions Bank in the name of SampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
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businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
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WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
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WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashierrsquos Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x7917 account and paid to
SampD Supporting Services
58 On or about June 11 2009 defendant MAURICE WILLIAM
CAMPBELL JR took ldquoLittle Sistersrdquo on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
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70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
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Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
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NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
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NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
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(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 10 2009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 23 2009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words ldquoSir Williamrdquo and ldquoLil Sisterrdquo
64 On or about September 29 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 1 2009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
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COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
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50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 28 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 1 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x7917 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 24 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Counts 3 through 58Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
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WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
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officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
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5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
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WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
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WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
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officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
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5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the ldquoLittle Sistersrdquo and make purchases for the ldquoLittle Sistersrdquo
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
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businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
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WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
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WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations of paragraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 28 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
COUNT DATE AMOUNT VENDOR
3 1252006 $102460 Reedrsquos Jewelers
4 312007 $18852 Just Add Water
5 3262007 $26814 Just Add Water
6 8202007 $13071 Jos A Bank
7 11232007 $53955 Gus Mayer
8 12242007 $96956 Jos A Bank
9 312008 $19607 Jos A Bank
10 3222008 $42181 Jos A Bank
11 5142008 $14904 Behind the Glass
12 7242008 $56635 White House Black Market
13 10222008 $76183 Coach
14 10222008 $104371 Coach
15 1292008 $71565 Bottega
16 12222008 $152110 Jos A Bank
17 1302009 $6107 Hooters
18 292009 $9874 Hooters
19 3142009 $16345 TJMaxx
20 3162009 $154440 UltraDiamonds
21 4232009 $18000 Triple S Trophies amp Engraving
22 3192009 $41340 Neiman Marcus
23 4172009 $82892 Neiman Marcus
24 5282009 $11080 Village Tavern
25 5282009 $111320 BeBe
29
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 29 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
26 6112009 $48760 Express
27 6112009 $8248 Banana Republic
28 6112009 $5456 Belk
29 6112009 $38795 Abercrombie amp Fitch
30 6112009 $22583 PF Changrsquos
31 6242009 $3980 Hooters
32 6242009 $112416 Coach
33 7132009 $4215 Hooters
34 7202009 $4469 Hooters
35 7272009 $36400 Urban Outfitters
36 7272009 $79398 BCBG
37 7272009 $29685 Fleming
38 812009 $175389 Coach
39 8142009 $87800 Coach
40 8252009 $25000 Baytowne Jewelers
41 8282009 $3832 Hooters
42 8282009 $177500 Baytowne Jewelers
43 9212009 $2012 Hooters
44 9212009 $154440 UltraDiamonds
45 10202009 $15000 Triple S Trophies amp Engraving
46 9222009 $11283 Belk
47 9282009 $19468 Francescarsquos
48 1092009 $20453 Belk
49 10272009 $40305 Jos A Bank
30
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
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WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
50 10292009 $20460 Francescarsquos
51 11292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 12142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 12162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
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WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
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WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
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officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009510 East Grand Avenue
Rainbow City AL 35906
60 9252009510 East Grand Avenue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 32 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
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THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Counts 61 through 91Money Laundering
Title 18 United States Code Sections 1956(a)(1)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
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Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATEINSTITUTE
CHECK NUMBER
AMOUNT DEPOSITEDINTO BHS ACCOUNT
x7917
61 9122007 788 $ 500000
62 1012007 794 $ 500000
63 1172007 815 $ 500000
64 12112007 842 $ 500000
65 1292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 512008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 34 of 41
70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 35 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
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NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
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(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
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70 722008 962 $ 600000
71 812008 989 $ 600000
72 932008 1016 $ 600000
73 1012008 1054 $ 600000
74 1132008 1077 $ 600000
75 1222008 1097 $ 600000
76 1152009 1145 $ 600000
77 222009 1162 $ 600000
78 332009 1179 $ 600000
79 412009 1214 $ 600000
80 562009 1247 $ 600000
81 612009 1272 $ 600000
82 712009 1298 $ 600000
83 842009 1347 $ 600000
84 922009 1372 $ 600000
85 1012009 1407 $ 600000
86 1122009 1439 $ 600000
87 1212009 1465 $ 600000
88 162010 1521 $ 600000
89 212010 1540 $ 600000
90 322010 1560 $ 600000
91 462010 1585 $ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
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Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
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NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
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omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
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NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Counts 92 through 96Money Laundering
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
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(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
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JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspiracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATEFUNDS
TRANSFERRED
ACCOUNT INTOWHICH FUNDS WERE
DEPOSITED
92 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 737 for $2500000
Baptist Housing ServicesLLC Account x7917
93 5102007
Alabama Small BusinessInstitute of CommerceCheck Number 738 for $1500000
Baptist Housing ServicesLLC Account x7917
94 812007
Alabama Small BusinessInstitute of CommerceCheck Number 777 for $1500000
Baptist Housing ServicesLLC Account x7917
95 4142009
Baptist HousingServices LLC CheckNumber 1044 for $1200000
Johnson Marketing GroupLLC Account x1459
96 582009Regions Bank CashierrsquosCheck 5002068436 for $2400000
SampD Supporting ServicesAccount x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
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WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
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officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
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5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
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Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
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Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
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NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981(a)(1)(C)
and Title 28 United States Code Section 2461(c)
2 Upon conviction of the offenses of wire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States of America pursuant to Title 18 United States
Code Section 981(a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 38 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed beyond the jurisdiction of the court
d has been substantially diminished in value or
e has been commingled with other property which cannot bedivided without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461(c)
All pursuant to 18 USC sect 981(a)(1)(C) and 28 USC sect 2461(c)
39
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NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
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the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
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Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
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State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
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State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
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of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
NOTICE OF FORFEITURE[18 USC sect 982(a)(1)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(1)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(1) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
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knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
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than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
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amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
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MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
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WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
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5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
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THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
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Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
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Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
s Foreperson of the Grand Jury
JOYCE WHITE VANCEUNITED STATES ATTORNEY
s Tamarra Matthews JohnsonAssistant United States Attorney
s George A MartinAssistant United States Attorney
41
Case 210-cr-00186-AKK -JEO Document 4 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
JWVTMJGAM March 2011 DTF GJ 8
7~1 lIR yenhfU~f~D STATES DISTRICT COURT FOR THE L ~~ (Tc~RtHERN DISTRICT OF ALABAMA
1Clrmiddot J-Lidh l SOUTHERN DIVISIONj
UNITED STATES OF AMERICA
v CRshy
MAURICE WILLIAM CAMPBELL JR SUPERSEDING also known as BILL CAMPBELL also known as SIR WILLIAM
Dekndant
INDICTMENT
THE GRAND JURY CHARGES
At all times material to this Superseding Indictment
Introduction
1 Defendant MAURICE WILLIAM CAMPBELL JR in or about
January 2003 was hired as the State Director of the Alabama Small Business
Development Consortium (the Consortium or ASBDC) The Consortium was
comprised of four-year institutions in the State of Alabama - each of which had its
own small business development center - as well as a procurement technical center
and an international trade center The ASBDCs purposes were to enhance
economic growth to provide management and technical assistance to small
1
FILED 2011 Mar-31 PM 0427US DISTRICT COURT
ND OF ALABAMA
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 1 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
businesses and to develop Alabamas workforce The State Directors office was
located at the University of Alabama at Birmingham in Birmingham Alabama and
subsequently at the University of Alabama in Tuscaloosa Alabama In his role as
State Director defendant MAURICE WILLIAM CAMPBELL JR in addition
to other duties was responsible for seeking and maintaining funding for the
Consortium and its small business development centers located at four-year
colleges in Alabama
2 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC) Defendant MAURICE WILLIAM
CAMPBELL JR was the President a director the initial registered agent and
incorporator of the Institute The stated purpose of the Institute was to enhance
economic development increase employment and reduce business failure in
Alabama through business education and workforce training The Institute was
formed as a nonprofit with the representation that the corporation shall not be
operated for private profit nor its assets at any time inure to the benefit ofany
shareholder member director trustee officer or other private person The
Institute was expressly organized exclusively for purposes authorized within
Section 501 (c )(3) of the Internal Revenue Code and for nonprofit purposes within
2
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 2 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 15 of 41
30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
the meaning of the Alabama Code
3 The Institute received nearly all of its funding from the State of Alabama
through grants contracts and appropriations in the education budget From 2005
through 2010 the private nonprofit Institute received over seven million three
hundred thousand dollars ($730000000) to provide education and training to
workers in the State of Alabama and perform other services consistent with the
Institutes stated purposes
Count One Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 From in or about August 2004 and continuing to in or about August
2005 in Jefferson Calhoun and Etowah Counties within the Northern District of
Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the State of Alabama Department of Finance and
others and to obtain money and property by means of materially false pretenses
representations and promises said scheme and artifice being in substance as
follows
3
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 3 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
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7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Purpose of the Scheme and Artifice
2 It was a part of the scheme and artifice that the defendant MAURICE
WILLIAM CAMPBELL JR would and did use his position as State Director of
the Alabama Small Business Development Consortium (ASBDC) to obtain
money belonging to the State of Alabama
3 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in August 2004 would and did cause a
letter from defendant CAMPBELL as State Director of the ASBDC in
Birmingham Alabama to be sent by facsimile to the Governor of the State of
Alabama in Montgomery Alabama requesting money for the ASBDC
4 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR in or about September 2004 would
and did cause the ASBDC to apply for state funds through a Project
Questionnaire
5 It was a further part of the scheme and artifice that the defendant
MAURICE ILLIAM CAMPBELL JR in or about September 2004 would
and did cause a Project Questionnaire to be completed and sent to private
counsel administering bond proceeds for the State The Project Questionnaire
identified the project for which State money was requested as the Jacksonville
4
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 4 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 15 of 41
30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
State University Small Business Development Consortium In the questionnaire
the project owner was identified as the Alabama Small Business Development
Consortium In the Use of the Project section the question stated Other than
the project owner identified above and individual members of the general public
will the project be used in the trade of business of any person (individual
corporation non-profit entity partnership limited liability company
proprietorship etc) other than a governmental unit If so provide details The
typed answer stated It will be used only by the ASBDC which is made up of the
following member institutions of the Alabama Small Business Development
Consortium University of Alabama at Birmingham University ofNorth Alabama
Alabama AampM University University ofAlabama at Huntsville University of
Alabama at Tuscaloosa Jacksonville State University Alabama State University
University of West Alabama Troy University and the University of South
Alabama
6 It was a further part of the scheme and artifice that in or about February
2005 the defendant MAURICE WILLIAM CAMPBELL JR would and did
cause to be incorporated the Alabama Small Business Institute of Commerce a
private nonprofit entity under federal and state law with defendant CAMPBELL
as President Director incorporator and registered agent
5
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 5 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
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WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
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the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
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Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
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NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
7 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR~ on or about May 312005 did cause
to be sent by facsimile to the Department ofFinance documents concerning the
ASBDC request for funding including a Total Program Cost Worksheet stating
the cost to run the ASBDC Program for 2 years
8 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about June 22005 did cause to
be mailed from the State Department ofFinance in Montgomery Alabama to
Jacksonville State University in Jacksonville Alabama a State Warrant in the
amount of$I50000000
9 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 7 2005 did cause to
be created at AmSouth Bank (now Regions Bank) in Gadsden Alabama an
account in the name of the Alabama Small Business Institute of Commerce
10 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about July 152005 as
President of the Alabama Small Business Institute of Commerce (The Institute)
did execute a written agreement with the Jacksonville State University Small
Business Development Center for The Institute to provide services to Jacksonville
6
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 6 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
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this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
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Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
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Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
State University for $120000000
11 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 12005 caused
Jacksonville State University to provide a check to The Institute in the amount of
$120000000
12 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR on or about August 42005 did cause
to be created at AmSouth Bank (now Regions Bank) a Certificate for Deposit in
the amount of $1 00000000 and did cause the interest from that Certificate of
Deposit to be transferred to another account in the name ofThe Institute
13 It was a further part of the scheme and artifice that the defendant
MAURICE WILLIAM CAMPBELL JR and others would and did use the
funds in The Institute accounts for personal benefit
The Mailinamp
14 On or about June 22005 the exact date being unknown to the Grand
Jury in Jefferson Etowah and Calhoun Counties within the Northern District of
Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury for the purpose
7
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 7 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 15 of 41
30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused State of Alabama warrant number 504478937 in
the amount of one million five hundred thousand dollars ($150000000) to be
placed in a post office and an authorized depository for mail matter to be sent by
the Postal Service and knowingly and willfully caused said warrant to be delivered
by mail according to the direction thereon from the State of Alabama Department
of Finance in Montgomery Alabama 36130 to Jacksonville State University 700
Pelham Road N Jacksonville Alabama 36265
All in violation of Title 18 United States Code Sections 1341 and 2
Count Two Conspiracy
Title 18 United States Code Section 371
THE CONSPIRACY
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 From in or about February 2005 and continuing until in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere the defendant
MAURICE WILLIAM CAMPBELL JR
8
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 8 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
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MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
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12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
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Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
knowingly and willfully conspired combined and agreed with other persons
known and unknown to the Grand Jury to commit offenses against the United
States that is
(A) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use ofUnited States mail or interstate carrier in violation of Title 18 United States Code Section 1341
(B) to devise and intend to devise a scheme and artifice to defraud the State ofAlabama and the private nonprofit Institute and to obtain money and property belonging to others by means of false and fraudulent pretenses representations and promises by use of interstate wire transmissions in violation of Title 18 United States Code Section 1343
(C) to conduct or attempt to conduct a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity or with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986 or knowing that the transaction is designed in whole or in part to conceal or disguise the nature the location the source the ownership or the control of the proceeds of specified unlawful activity or to avoid a transaction reporting requirement under State or Federal law in violation of Title 18 United States Code Section 1956(a)(1) and
(D) to engage or attempt to engage in a monetary transaction in criminally derived property of a value greater than $10000 and that is derived from specified unlawful activity in violation of Title 18 United States Code Section 1957
9
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 9 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 15 of 41
30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
MANNER AND MEANS OF THE CONSPIRACY
3 It was a part of the conspiracy that defendant MAURICE WILLIAM
CAMPBELL JR would and did use his position and authority as State Director
of the Consortium to gain access to state officials - including legislators personnel
at the Finance Department and the President Deans and other personnel at
Jacksonville State University
4 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did represent to state officials that he
sought funding for his nonprofit the Institute to serve the same mission of
education and training for Alabama workers as well as small business
development
6 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the conspiracy that the Institute received more
10
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 10 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 15 of 41
30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
than seven million three hundred thousand dollars ($730000000) in state funding
8 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did establish various bank
accounts in the name of the Institute at AmSouth bank now Regions Bank into
which state funds were deposited and transferred
9 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did receive direct access to
the bank accounts of the Institute through checkcards and would and did use those
checkcards to make over one million dollars in purchases including jewelry
clothing personal services food lodging and gas
10 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained bythe Institute to purchase a one million dollar certificate of deposit the
interest on which was deposited into the account from which checkcard
transactions were made
11 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to purchase and lease vehicles including a Mercedes a
Yukon Denali and two Honda Pilots
11
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 11 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 15 of 41
30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
12 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to pay themselves hundreds of thousands of dollars in
salaries and benefits
13 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
14 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute to issue tens of thousands of dollars in checks to women
called the Little Sisters and to make purchases for the Little Sisters
15 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did divert hundreds of
thousands of dollars of state funding obtained by the Institute to bank accounts at
Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services as well as an
account at Compass Bank in the name ofBaptist Health Services
16 It was a further part of the conspiracy that defendant MAURICE
12
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 12 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 13 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 14 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 15 of 41
30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
WILLIAM CAMPBELL JR and others were issued checkcards on these
accounts In addition to his Institute business checkcard defendant MAURICE
WILLIAM CAMPBELL JR had checkcards issued to him on the Baptist
Housing Services LLC Johnson Marketing Group LLC and SampD Supporting
Services accounts
17 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others issued checks to the Little Sisters
from these additional accounts
18 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did provide less than twenty
percent of the state funding obtained by the Institute to the public four-year
colleges and universities that were members of the Consortium
19 It was a further part of the conspiracy that defendant MAURICE
WILLIAM CAMPBELL JR and others did not disclose to state officials
including legislators officials at Jacksonville State University or officials at the
Universities of other Consortium members how the state money provided to the
Institute was being spent and did disguise and misrepresent expenditures in the
books and records of the Institute
13
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OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
OVERT ACTS
20 In furtherance of the conspiracy and to achieve the objects thereof
defendant MAURICE WILLIAM CAMPBELL JR and others committed and
caused to be committed the following overt acts among others in the Northern
District of Alabama and elsewhere
21 In or about February 2005 defendant MAURICE WILLIAM
CAMPBELL JR incorporated the Alabama Small Business Institute of
Commerce (the Institute or ASBIC)
22 In or about July 2005 defendant MAURICE WILLIAM
CAMPBELL JR the Bookkeeper of the Institute and a Director of the Institute
completed paperwork and opened a bank account for the Alabama Small Business
Institute of Commerce the Operating Account (x5227) at AmSouth bank now
Regions Bank
23 On or about June 21 2005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide faculty staff and facilities
to assist the Consortium and Jacksonville State in providing information
technology workforce development for $9560000
24 On or about July 27 2005 defendant MAURICE WILLIAM
14
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CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
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Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
CAMPBELL JR caused a check from Jacksonville State for $9560000 to be
deposited into the Operating Account of the Institute
25 On or about June 2 2005 defendant MAURICE WILLIAM
CAMPBELL JR caused State of Alabama officials to mail a check for
$1500000 to Jacksonville State University
26 On or about July 152005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State ofAlabama for $120000000
27 On or about August 22005 defendant MAURICE WILLIAM
CAMPBELL JR and others caused a check for $120000000 from Jacksonville
State University to be deposited into the Operating Account of the Institute
28 On or about August 4 2005 defendant MAURICE WILLIAM
CAMPBELL JR and a Director of the Institute established a $1000000
certificate of deposit with AmSouth Bank now Regions Bank the interest on
which was deposited into the Travel Account of the Institute
29 On or about August 9 2005 defendant MAURICE WILLIAM
CAMPBELL JR and others opened another Institute account the Travel
Account (x5873) at AmSouth Bank now Regions Bank
15
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30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 16 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
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NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
30 On or about October 12005 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for the Institute to provide services to educate and
train workers in the State of Alabama for $40000000 In the ensuing months
defendant MAURICE WILLIAM CAMPBELL JR and others retrieved checks
from Jacksonville State issued by the University pursuant to this agreement
31 On or about October 12006 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $120000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
32 In or about September 2006 defendant MAURICE WILLIAM
CAMPBELL JR hired the Executive Director of the Institute
33 In or about October 2006 defendant MAURICE WILLIAM
CAMPBELL JR caused checkcards to be issued to the Executive Director of the
Institute and the Head of Marketing at the Consortium
16
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34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
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of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
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NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
34 On or about December 5 2006 defendant MAURICE WILLIAM
CAMPBELL JR purchased items from Reeds Jewelers for $102460 using his
Institute checkcard
35 On or about May 112007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper of the Institute opened an account (x7917)
in the name of Baptist Housing Services LLC at AmSouth Bank now Regions
bank
36 On or about May 10 2007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 737 in the
amount of $2500000 for Jan Feb March April amp May Rent to be issued to
Baptist Housing Services and deposited into the Baptist Housing Services LLC
x7917 account
37 On or about May 102007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number738 in the
amount of$1500000 for Oct Nov amp Dec Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x7917
account
38 On or about August 12007 defendant MAURICE WILLIAM
CAMPBELL JR and the Bookkeeper caused Institute check number 777 in the
17
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 17 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
amount of $1500000 for June July August Rent to be issued to Baptist
Housing Services and deposited into the Baptist Housing Services LLC x791 7
account
39 On or about September 122007 and on a monthly basis for the
remainder of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $5000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x7917 account
40 On or about October 12007 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $161000000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR and others retrieved checks from
Jacksonville State issued by the University pursuant to this agreement
41 On or about November 232007 defendant MAURICE WILLIAM
CAMPBELL JR purchased an item at Gus Mayer for $53955 using his Institute
checkcard
42 On or about January 29 2008 and on a monthly basis for the remainder
18
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 18 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
of2007 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
43 On or about June 30 2008 the Executive Director of the Institute
purchased items at Coach in Foley Alabama using his Institute checkcard in the
amount of$I93099
44 On or about August 6 2008 the Executive Director of the Institute
incorporated Johnson Marketing Group LLC
45 On or about August 7 2008 the Executive Director of the Institute
opened an account in the name of Johnson Marketing Group LLC (xI459) at
Regions Bank Checkcards on this account were issued to the Executive Director
of the Institute and defendant MAURICE WILLIAM CAMPBELL JR
46 On or about October 12008 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $187500000 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
19
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 19 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Jacksonville State issued by the University pursuant to this agreement
47 On or about December 2 2008 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $434312 using funds
from the Institute
48 On or about December 92008 the defendant MAURICE WILLIAM
CAMPBELL JR issued $200 checks to three of the Little Sisters and treated
them to dinner at Bottega which was paid for on the Bookkeepers Institute
checkcard in the amount of$71565
49 On or about January 152009 and on a monthly basis for the remainder
of2009 defendant MAURICE WILLIAM CAMPBELL JR and the
Bookkeeper caused Institute checks for $6000 to be issued to Baptist Housing
Services and deposited into the Baptist Housing Services LLC x791 7 account
50 On or about February 20 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $28482 using funds from
the Institute
51 On or about March 16 2009 the Executive Director of the Institute
purchased items at UltraDiamonds via the Internet using his Institute checkcard in
20
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 20 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
the amount of$I54440
52 On or about April 23 2009 the Executive Director purchased engraving
services at Triple S Trophies located in Gadsden Alabama using his Institute
checkcard in the amount of $18000 to have bracelets engraved with the words Sir
William and Lil Sister
53 In or about April 2009 defendant MAURICE WILLIAM
CAMPBELL JR on behalf ofBaptist Housing Services and the Executive
Director of the Institute on behalf of Johnson Marketing Group LLC executed an
agreement for Johnson Marketing Group LLC to provide marketing services to
Baptist Housing Services for $1200000
54 On or about April 14 2009 a check for $1200000 was issued from
Baptist Housing Services LLC Account x7917 to Johnson Marketing Group
55 On or about April 29 2009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC x7917 account check for $182261 using funds from the
Institute
56 On or about May 6 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused an employee ofRegency Pointe to open an account at
Regions Bank in the name ofSampD Supporting Services (x4750) Checkcards on
21
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 21 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
this account were issued to the Regency Pointe employee and defendant
MAURICE WILLIAM CAMPBELL JR
57 On or about May 8 2009 defendant MAURICE WILLIAM
CAMPBELL JR caused a Cashiers Check in the amount of $2400000 to be
purchased by Baptist Housing Services LLC from the x791 7 account and paid to
SampD Supporting Services
58 On or about June 112009 defendant MAURICE WILLIAM
CAMPBELL JR took Little Sisters on a shopping trip at the Summit in
Birmingham Alabama using a VISA credit card issued to him
59 On or about June 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $190913 using funds
from the Institute
60 On or about July 292009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $75806 using funds from
the Institute
61 On or about September 3 2009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
22
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 22 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Housing Services LLC Regions Bank account check for $62379 using funds from
the Institute
62 On or about September 102009 the Executive Director purchased
items at UltraDiamonds via the Internet using his Institute checkcard in the
amount of $154440
63 On or about October 232009 the Executive Director purchased
engraving services at Triple S Trophies located in Gadsden Alabama using his
Institute checkcard in the amount of $15000 to have bracelets engraved with the
words Sir William and Lil Sister
64 On or about September 292009 the bill for the VISA credit card used
by defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $76191 using funds from
the Institute
65 On or about October 12009 defendant MAURICE WILLIAM
CAMPBELL JR executed an agreement on behalf of the Institute with
Jacksonville State University for a strategic partnership to further the common
goals of education training and workforce development in which the Institute
would receive $173498600 for the operation of Institute programs for education
training and workforce development In the ensuing months defendant
23
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 23 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
MAURICE WILLIAM CAMPBELL JR caused others to retrieve checks from
Jacksonville State issued by the University pursuant to this agreement
66 On or about October 282009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $49703 using funds from
the Institute
67 On or about December 12009 the bill for the VISA credit card used by
defendant MAURICE WILLIAM CAMPBELL JR was paid with a Baptist
Housing Services LLC Regions Bank account check for $102597 using funds
from the Institute
68 On or about January 6 2010 and on a monthly basis through March
2010 defendant MAURICE WILLIAM CAMPBELL JR and the Bookkeeper
caused Institute checks for $600000 to be issued to Baptist Housing Services and
deposited into the Baptist Housing Services LLC x791 7 account
All in violation of Title 18 United States Code Section 371
24
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 24 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Counts 3 throueh 58 Wire Fraud
Title 18 United States Code Sections 1343 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
Purpose of the Scheme and Artifice
3 From in or about February 2005 and continuing to in or about April
2010 the exact dates being unknown in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the grand jury did knowingly
and with the intent to defraud devise and intend to devise a scheme and artifice to
defraud the State of Alabama the Institute and others and to obtain money and
property belonging to the Institute and the State of Alabama by means of
materially false and fraudulent pretenses representations and promises
4 It was a part of the scheme and artifice that defendant MAURICE
25
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 25 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
WILLIAM CAMPBELL JR would and did represent to state officials that he
was seeking funding for the Consortium for the education and training for
Alabama workers as well as small business development
5 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did represent to state
officials that he sought funding for his nonprofit the Institute to serve the same
mission of education and training for Alabama workers as well as small business
development
6 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR would and did seek state funding for the Institute
through grants contracts and appropriations in the state education budget
7 It was a further part of the scheme and artifice that the Institute received
more than seven million three hundred thousand dollars ($730000000) in state
funding
8 It was a further part of the scheme and artifice that defendant MAURICE
WILLIAM CAMPBELL JR and others would and did use state funding
obtained by the Institute for the benefit of themselves their families and their
friends
9 It was a further part of the scheme and artifice that defendant MAURICE
26
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 26 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
WILLIAM CAMPBELL JR would and did cause the creation of bank accounts
at Regions Bank in the name of other entities including Baptist Housing Services
LLC Johnson Marketing Group LLC and SampD Supporting Services
10 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did have issued to him
checkcards on the accounts of Baptist Housing Services LLC Johnson Marketing
Group LLC and SampD Supporting Services which he used to make expenditures
for his personal benefit in addition to his Institute business checkcard
11 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause funds diverted
from the Institute to accounts in the names of other entities to be used to write
checks to the Little Sisters and make purchases for the Little Sisters
12 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR would and did cause state funding
obtained by the Institute and transferred from the Institute to the Baptist Housing
Services LLC Regions Bank account to be used to pay charges on a VISA credit
card issued to him
13 It was a further part of the scheme and artifice that defendant
MAURICE WILLIAM CAMPBELL JR and others did not disclose to state
27
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 27 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
officials including legislators officials at Jacksonville State University or
officials at the Universities of other Consortium members how the state money
provided to the Institute was being spent and did disguise and misrepresent
expenditures in the books and records of the Institute
THE WIRE COMMUNICATION
14 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so did
transmit and cause to be transmitted in interstate commerce by means of a wire
communication certain signs and signals that is defendant MAURICE
WILLIAM CAMPBELL JR caused an interstate communication between
Alabama and another state to be made on each occasion listed below
15 The allegations ofparagraphs 1 through 14 above are realleged for each
of Counts 3 through 58 below as though fully set forth therein
28
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 28 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
5
10
15
20
25
COUNT DATE
3 1252006
4 3112007
3262007
6 8202007
7 111232007
8 121242007
9 3112008
3222008
11 51142008
12 7242008
13 10222008
14 10222008
1292008
16 12222008
17 11302009
18 292009
19 31142009
31162009
21 4232009
22 31192009
23 41172009
24 5282009
5282009
AMOUNT
$102460
$18852
$26814
$13071
$53955
$96956
$19607
$42181
$14904
$56635
$76183
$104371
$71565
$152110
$6107
$9874
$16345
$154440
$18000
$41340
$82892
$11080
$111320
29
VENDOR
Reeds Jewelers
Just Add Water
Just Add Water
Jos A Bank
Gus Mayer
Jos A Bank
Jos A Bank
Jos A Bank
Behind the Glass
White House Black Market
Coach
Coach
Bottega
Jos A Bank
Hooters
Hooters
TJMaxx
UltraDiamonds
Triple S Trophies amp Engraving
Neiman Marcus
Neiman Marcus
Village Tavern
BeBe
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 29 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
26 61112009
27 61112009
28 6112009
29 6112009
30 61112009
31 6242009
32 62412009
33 7132009
34 7202009
35 7272009
36 7272009
37 7272009
38 812009
39 8142009
40 8252009
41 8282009
42 8282009
43 92112009
44 92112009
45 10202009
46 9222009
47 9282009
48 1092009
49 10272009
$48760
$8248
$5456
$38795
$22583
$3980
$112416
$4215
$4469
$36400
$79398
$29685
$175389
$87800
$25000
$3832
$177500
$2012
$154440
$15000
$11283
$19468
$20453
$40305
30
Express
Banana Republic
Belk
Abercrombie amp Fitch
PF ChangS
Hooters
Coach
Hooters
Hooters
Urban Outfitters
BCBG
Fleming
Coach
Coach
Baytowne Jewelers
Hooters
Baytowne Jewelers
Hooters
UltraDiamonds
Triple S Trophies amp Engraving
Belk
Francescas
Belk
Jos A Bank
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 30 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
50 10292009 $20460 Francescas
51 111292009 $38176 Macys
52 1252009 $29419 Belk
53 1252009 $15238 Belk
54 12142009 $10006 Macys
55 121142009 $24172 Macys
56 12142009 $12235 Express
57 12162009 $28010 Express
58 121162009 $11878 Banana Republic
All in violation of Title 18 United States Code Sections 1343 and 2
Counts 59 and 60 Mail Fraud
Title 18 United States Code Sections 1341 and 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
31
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 31 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
THE MAILING
4 On or about the dates set forth below each such date constituting a
separate count of this Indictment in Jefferson Calhoun and Etowah Counties
within the Northern District of Alabama and elsewhere defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury for the purpose
of executing the above-described scheme and artifice and attempting to do so
knowingly and willfully caused a shipment of bracelets to be sent by a private
carrier to wit United Parcel Service and willfully caused said shipments to be
delivered according to the direction thereon
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 59 and 60 below as though fully set forth therein
COUNT DATE DELIVERED TO
59 3272009 510 East Grand A venue
Rainbow City AL 35906
60 9252009 510 East Grand A venue
Rainbow City AL 35906
All in violation of Title 18 United States Code Sections 1341 and 2
32
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 32 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Counts 61 through 91 Money Laundering
Title 18 United States Code Sections 1956(a)(I)(B)(i) amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 19 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 13 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
conducted and attempted to conduct a financial transaction in and affecting
interstate commerce that is transfer of the monetary instrument referenced in each
Count below a check from the x5227 account of the Alabama Small Business
33
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 33 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Institute of Commerce which involved the proceeds of specified unlawful activity
that is mail fraud wire fraud and conspiracy to the x7917 account of Baptist
Housing Services LLC knowing that each transaction was designed in whole and
in part to conceal and disguise the nature location source ownership and control
of the proceeds of said specified unlawful activity and that while conducting and
attempting to conduct such financial transaction knew that the property involved
in each financial transaction that is the monetary instrument described below was
proceeds of some form of unlawful activity
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 61 and 91 as though fully set forth therein
COUNT DATE INSTITUTE
CHECK NUMBER
AMOUNT DEPOSITED INTO BHS ACCOUNT
x7917
61 91122007 788 $ 500000
62 1012007 794 $ 500000
63 11172007 815 $ 500000
64 121112007 842 $ 500000
65 11292008 863 $ 600000
66 242008 871 $ 600000
67 342008 892 $ 600000
68 5112008 924 $ 600000
69 622008 944 $ 600000
34
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 34 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
70 722008
71 812008
72 932008
73 1012008
74 11132008
75 1222008
76 11152009
77 222009
78 332009
79 412009
80 562009
81 612009
82 7112009
83 842009
84 922009
85 1012009
86 1122009
87 1212009
88 1162010
89 212010
90 322010
91 462010
962
989
1016
1054
1077
1097
1145
1162
1179
1214
1247
1272
1298
1347
1372
1407
1439
1465
1521
1540
1560
1585
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
$ 600000
All in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i)
and 2
35
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 35 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
Counts 92 throu~h 96 Money Launderin~
Title 18 United States Code Sections 1957 amp 2
1 The Grand Jury repeats and realleges the allegations contained in
paragraphs 1 through 3 of the Introduction to this Indictment as though fully set
out herein
2 The Grand Jury repeats and realleges the allegations contained in
paragraphs 3 through 13 of Count Two of this Indictment as though fully set out
herein
3 The Grand Jury repeats and realleges the allegations contained in
paragraphs 4 through 19 of Counts 3 through 58 of this Indictment as though fully
set out herein
4 On or about each of the dates set forth in each Count below in Jefferson
Calhoun and Etowah Counties within the Northern District of Alabama the
defendant
MAURICE WILLIAM CAMPBELL JR
aided and abetted by others known and unknown to the Grand Jury knowingly
engaged in and attempted to engage in a monetary transaction by through and to
a financial institution in and affecting interstate commerce in criminally derived
property of a value greater than $1000000 that is the transfer of funds in the
36
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 36 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
amount set forth below into the account listed below such property having been
derived from a specified unlawful activity that is mail fraud wire fraud and
conspIracy
5 The allegations of paragraphs 1 through 4 above are realleged for each of
Counts 92 and 96 as though fully set forth therein
COUNT DATE FUNDS
TRANSFERRED
Alabama Small Business
92 5102007 Institute ofCommerce Check Number 737 for $2500000
Alabama Small Business
93 5102007 Institute of Commerce Check Number 738 for $1500000
Alabama Small Business
94 812007 Institute of Commerce Check Number 777 for $1500000
Baptist Housing
95 41412009 Services LLC Check Number 1044 for $1200000
Regions Bank Cashiers 96 582009 Check 5002068436
for $2400000
ACCOUNT INTO WHICH FUNDS WERE
DEPOSITED
Baptist Housing Services LLC Account x791 7
Baptist Housing Services LLC Account x7917
Baptist Housing Services LLC Account x791 7
Johnson Marketing Group LLC Account x1459
SampD Supporting Services Account x4750
All in violation of Title 18 United States Code Sections 1957 and 2
37
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 37 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
NOTICE OF FORFEITURE
[ 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)]
1 The allegations contained in Counts One through Sixty of this
Indictment are hereby realleged and incorporated by reference for the purpose of
alleging forfeiture pursuant to Title 18 United States Code Section 981 (a)(1 )(C)
and Title 28 United States Code Section 2461 (c)
2 Upon conviction of the offenses ofwire fraud and mail fraud in
violation of Title 18 United States Code Sections 1341 and 1343 set forth in
Counts One and Three through Fifty-Eight and upon conviction of the offense of
conspiracy in violation of Title 18 United States Code Section 371 set forth in
Count Two of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States ofAmerica pursuant to Title 18 United States
Code Section 981 (a)(1)(C) and Title 28 United States Code Section 2461(c) any
property real or personal which constitutes or is derived from proceeds traceable
to the offenses The property to be forfeited includes but is not limited to the
aggregate sum of seven million three hundred twenty-six thousand five hundred
sixty-nine dollars and two cents $732656902
3 If any of the property described above as a result of any act or
38
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 38 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
bullbull
omission of the defendant
a cannot be located upon the exercise of due diligence
b has been transferred or sold to or deposited with a third party
c has been placed 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 without difficulty
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21 United States Code Section 853(p) as incorporated by Title
28 United States Code Section 2461 (c)
All pursuant to 18 USC sect 981(a)(I)(C) and 28 USC sect 2461(c)
39
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 39 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
NOTICE OF FORFEITURE [18 USC sect 982(a)(I)]
1 The allegations contained in Counts Sixty-One through Ninety-Six of this
Indictment are incorporated by reference herein for the purpose of alleging
criminal forfeiture pursuant to Title 18 United States Code Section 982(a)(I)
FORFEITURE
2 As a result of the foregoing offenses alleged in Counts Sixty-One through
Ninety-Six of this Indictment the defendant
MAURICE WILLIAM CAMPBELL JR
shall forfeit to the United States any property real or personal involved in such
offenses committed by defendant MAURICE WILLIAM CAMPBELL JR or
any property traceable to such property The property to be forfeited includes but
is not limited to the aggregate sum of two hundred seventy-three thousand dollars
$27300000 and all interest and proceeds derived therefrom
3 If any of the property described above as being subject to forfeiture
pursuant to Title 18 United States Code Section 982(a)(I) as a result of any act or
omission of defendant MAURICE WILLIAM CAMPBELL JR
(1) cannot be located upon the exercise of due diligence
(2) has been transferred to sold to or deposited with a third person
(3) has been placed beyond the jurisdiction of the Court
40
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 40 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
(4) has been substantially diminished in value or
(5) has been commingled with other property that cannot be
subdivided without difficulty
it is the intent of the United States pursuant to Title 21 United States Code
Section 853(p) to seek forfeiture of any other property of said defendant
MAURICE WILLIAM CAMPBELL JR up to the value of the above
forfeitable property
All pursuant to Title 18 United States Code Section 982(a)(1)
A TRUE BILL
JOYCE WHITE VANCE
~ Assistant United S y
41
Case 210-cr-00186-AKK -JEO Document 4-1 Filed 033011 Page 41 of 41
