Indictment Brindley Thompson
Indictment Brindley Thompson
Indictment Brindley Thompson
)
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v.
BEAU B. BRINDLEY and
MICHAEL THOMPSON,
Defendants.
Case No.14-CR-468
Violations: Title 18, United States
Code, Sections 371, 1512(c)(2), and
1623(a)
SUPERSEDING INDICTMENT
COUNT ONE
The SPECIAL FEBRUARY 2014 GRAND JURY charges:
1.
located in Chicago.
The Law Office of Beau B. Brindley and Associates was a law firm
It was primarily in the business of representing individuals charged with
District of Illinois, in violation of Title 18, United States Code, Section 1623(a); and (ii) to
obstruct, influence, and impede official proceedings, in violation of Title 18, United States Code,
Section 1512(c)(2).
Relevant Legal Proceedings
United States of America v. Alexander Vasquez
a.
District of Illinois returned a two-count indictment charging Carlos Cruz, Joel Perez, and
Alexander Vasquez with conspiring to and attempting to knowingly and intentionally possess
with intent to distribute a controlled substance, in violation of Title 21, United States Code,
Section 846.
Carlos Cruz and Joel Perez pleaded guilty to the charge of conspiring to
commenced as a jury trial in the United States District Court for the Northern District of Illinois.
c.
d.
Marina Collazo testified under oath in the trial of United States of America
The following issues were material in the trial of United States of America
v. Alexander Vasquez, Case Number 08-CR-625: (i) the reason why Alexander Vasquez drove a
Pontiac Bonneville to Arlington Heights, Illinois on August 5, 2008; (ii) whether Marina Collazo
had asked Alexander Vasquez to drive the Pontiac Bonneville to Arlington Heights and gave him
the keys to the Bonneville; and (iii) whether Marina Collazo had been induced to testify falsely
about those issues.
On or about March 27, 2008, a federal grand jury in the Northern District
of Illinois returned a six-count indictment charging Bennie Wilcox with sending interstate
communications with the intent to annoy, abuse, harass, and threaten another person, in violation
of Title 18, United States Code, Section 875(c), and Title 47, United States Code, Section
223(a)(1)(C).
The case against Bennie Wilcox commenced as a jury trial in the United
The following issues were material in the trial of United States of America
v. Bennie Wilcox, Case Number 08-CR-256: (i) whether Bennie Wilcox had accessed email
accounts belonging to J.H. from his office on June 6, 2007 and June 8, 2007; (ii) whether Karilyn
Wilcox had disclosed the user name and password to Bennie Wilcoxs email account to Mary;
and (iii) Karilyn Wilcoxs credibility.
United States of America v. Richard Harrington
k.
On or about June 23, 2010, a federal grand jury in the Northern District of
Illinois returned a superseding indictment charging Richard Harrington with various crimes
related to the distribution of heroin, in violation of Title 21, United States Code, Sections 841, 843,
and 846; possession of a firearm in furtherance of a drug trafficking offense, in violation of Title
18, United States Code, Section 924(c); and money laundering, in violation of Title 18, United
States Code, Section 1956. The case was assigned case number 09-CR-814.
l.
conspiring to possess heroin with intent to distribute, distribution of heroin, and money laundering.
The charge of possession of a firearm in furtherance of a drug trafficking offense commenced as a
jury trial in the Northern District of Illinois.
n.
The following issues were material in the trial of United States of America
v. Richard Harrington, Case Number 09-CR-814: (i) Richard Harringtons possession of a .40
caliber Smith and Wesson firearm; (ii) Richard Harringtons knowledge of the presence of a .40
caliber Smith and Wesson firearm in his vehicle on October 7, 2009; and (iii) whether Richard
Harrington possessed the .40 caliber Smith and Wesson firearm in furtherance of his drug
trafficking activities.
United States of America v. Isaac Myles
p.
Illinois returned a four-count superseding indictment charging Isaac Myles with unlawful
possession of a firearm, in violation of Title 18, United States Code, Section 922(g)(1);
possession with intent to distribute heroin, in violation of Title 21, United States Code, Section
841; and possession of a firearm in furtherance of a drug trafficking offense, in violation of Title
18, United States Code, Section 924(c)(1)(A).
q.
r.
The case against Isaac Myles commenced as a jury trial in the United
On or about August 21, 2012, Isaac Myles testified under oath during his
t.
The following issues were material in the trial of United States of America
trial.
v. Isaac Myles, Case Number 10-CR-647: (i) when and why Isaac Myles purchased a .22 caliber
RG industry revolver; and (ii) whether Isaac Myles possessed the .22 caliber RG industry
revolver in furtherance of his drug trafficking activities.
United States of America v. Rahshone Burnett
u.
Illinois returned a superseding indictment that charged Rahshone Burnett with conspiring to
distribute one kilogram or more of heroin, in violation of Title 21, United States Code, Section
846; and possession with intent to distribute heroin, in violation of Title 21, United States Code,
Section 841(a)(1), among other offenses.
v.
The case against Rahshone Burnett commenced as a jury trial in the United
States District Court for the Northern District of Illinois. Between February 4, 2013, and
February 6, 2013, Richard Harrington testified under oath during Burnetts trial.
x.
The following issues were material in the trial of United States of America
v. Rahshone Burnett, Case Number 09-CR-1030: (i) whether Richard Harrington and Rahshone
Burnett pooled their money to buy heroin; and (ii) whether Rahshone Burnett always paid Richard
Harrington for heroin before receiving it.
On or about February 5, 2010, in the United States District Court for the
Northern District of Illinois, David Conrad was convicted of committing multiple federal crimes,
in the case of United States of America v. David Conrad, Case Number 05-CR-931.
z.
On or about April 5, 2010, the United States District Court revoked David
Conrads bond, and Conrad was imprisoned at the Metropolitan Correctional Center in Chicago.
Defendant BEAU B. BRINDLEY was attempting to keep Conrad released until his sentencing.
bb.
stated the following with respect to Conrads physical condition during the meeting between
BRINDLEY and Conrad: The meeting was rendered very difficult by Mr. Conrads extreme
illness.
. The meeting was twice interrupted by Mr. Conrad leaving the room to vomit.
In RE: A Witness Before the Special September 2012 Grand Jury
cc.
On or about July 31, 2012, a federal grand jury in the Northern District of
Illinois returned a fifteen-count indictment charging David Price with drug trafficking, money
laundering, and unlawful possession of a firearm.
12-CR-587.
dd.
federal grand jury in the Northern District of Illinois were investigating a murder and other
violations of federal law.
ff.
before the Special September 2012 grand jury convened in the Northern District of Illinois.
The grand jury subpoena required Individual A to appear and give testimony before the grand
jury on October 23, 2012.
Manner and Means of the Conspiracy
3.
The manner and means by which defendants sought to accomplish the objects and
District of Illinois.
b.
District of Illinois.
c.
d.
e.
The false testimony was presented during criminal trials in the Northern
District of Illinois.
f.
States District Court for the Northern District of Illinois and to the United States Attorneys
Office for the Northern District of Illinois.
g.
Acts done in furtherance of the conspiracy were concealed and hidden, and
In furtherance of the conspiracy, and to accomplish its objects and purpose the
defendants committed and caused to be committed the following overt acts, among others:
United States of America v. Alexander Vasquez
a.
solicited Joel Perez to plead guilty to the indictment without implicating Vasquez in the factual
basis of a plea agreement.
b.
rehearsed multiple versions of a direct examination with Alexander Vasquez in the event
Vasquez testified on his own behalf.
false explanation as to why Vasquez was driving a Pontiac Bonneville on August 5, 2008.
e.
f.
testified falsely during the trial of Alexander Vasquez, as directed by BEAU B. BRINDLEY and
as alleged in Counts Two, Three, and Four of this Superseding Indictment.
g.
prison.
During the visit, Vasquez informed BRINDLEY that representatives from the U.S.
Department of Justice had visited Vasquez and asked Vasquez about perjury committed during
his trial.
On or about June 2, 2013, through on or about June 20, 2013, BEAU B. BRINDLEY
contacted Attorney C and asked Attorney C to attempt to prevent the U.S. Department of Justice
representatives from speaking to Vasquez. Attorney C was a personal injury and workers
compensation attorney and had no experience in criminal law.
an Assistant U.S. Attorney that he was exercising Mr. Vasquezs Fifth Amendment rights on his
behalf and was requesting that no agents attempt to speak with Mr. Vasquez until Ive had a
chance to meet with him, all in an attempt to prevent U.S. Department of Justice representatives
from speaking to Vasquez.
United States of America v. Bennie Wilcox
i.
defense witness Karilyn Wilcox to testify falsely at the trial of Bennie Wilcox.
THOMPSON
directed Karilyn Wilcox to testify that she disclosed the user name and password to Bennie
false.
j.
directed by MICHAEL THOMPSON and as alleged in Counts Six, Seven, and Eight of this
Superseding Indictment.
United States of America v. Richard Harrington
k.
BRINDLEY
instructed Harrington to deny ownership of a .40 caliber Smith and Wesson firearm found in
Harringtons car at the time of his arrest on October 7, 2009, which testimony BRINDLEY knew
to be false.
l.
Harringtons possession of a .40 caliber Smith and Wesson firearm found in Harringtons car at
the time of his arrest on October 7, 2009. Harrington was directed to memorize the answers
contained in the proposed direct examinations.
m.
and other attorneys from the Law Office of Beau B. Brindley and Associates rehearsed prepared
direct examinations with Richard Harrington.
contained a false denial as to Harringtons possession of a .40 caliber Smith and Wesson firearm.
10
n.
directed by BRINDLEY and as alleged in Counts Ten, Eleven, and Twelve of this Superseding
Indictment.
United States of America v. Isaac Myles
o.
Between on or about February 16, 2012, and August 21, 2012, BEAU B.
BRINDLEY directed
Myles to falsely deny that he possessed a .22 caliber firearm in furtherance of drug trafficking
activities, and falsely testify as to when and why he bought the .22 caliber firearm, all of which
BRINDLEY knew would be false.
p.
Between on or about February 16, 2012, and August 21, 2012, BEAU B.
BRINDLEY rehearsed multiple versions of a direct examination with Myles to prepare him to
testify falsely at his own trial. The proposed direct examinations contained false denials as to
Myless possession and use of a .22 caliber firearm found in Myless residence at the time of his
arrest on December 16, 2009.
and as alleged in Counts Fourteen, Fifteen, and Sixteen of this Superseding Indictment.
United States of America v. Rahshone Burnett
r.
BRINDLEY directed Richard Harrington to testify at the trial of Rahshone Burnett that
Harrington did not pool money with Burnett in order to buy heroin; and that he did not give
11
BRINDLEY presented the false testimony of Richard Harrington at the trial of Rahshone
Burnett.
Metropolitan Correctional Center in Chicago. On April 7, 2010, after the meeting with Conrad,
BEAU B. BRINDLEY and MICHAEL THOMPSON prepared and filed a Status Report with
the United States District Court for the Northern District of Illinois.
BRINDLEY and THOMPSON falsely stated the following with respect to Conrads physical
condition during the meeting between BRINDLEY and Conrad:
profusely during the meeting.
12
On or about October 23, 2012, in response to the October 16, 2012 grand
jury subpoena served on Individual A, a letter was sent from the Law Offices of Beau B.
Brindley to an Assistant U.S. Attorney in the Northern District of Illinois.
signed and sent by THOMPSON.
represent [Individual A], who has been subpoenaed to testify before a grand jury on todays date,
October 23, 2012 . . . this letter provides notice of [Individual As] intent to assert her Fifth
Amendment rights and decline to answer any substantive questions posed to her if called before
the grand jury, all of which THOMPSON and BRINDLEY knew to be false.
In response to
the letter, Individual As grand jury appearance on October 23, 2012 was cancelled.
All in violation of Title 18, United States Code, Section 371.
13
COUNT TWO
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about August 27, 2009, at Chicago, in the Northern District of Illinois,
BEAU BRINDLEY
knowingly caused the making of a false material declaration under oath in the United States
District Court during the trial of United States v. Alexander Vasquez, Case Number 08-CR-625,
when BRINDLEY asked the following questions and Marina Collazo gave the following
answers:
Q.
Do you remember approximately what time [Joel Perez] left with his friend?
A.
Q.
And was it after that that you asked Alexander [Vasquez] that if he would go and
pick him up?
A.
Q.
A.
Yes.
Yes?
Yes.
Defendant BRINDLEY knew that this testimony was false because he knew Marina
Collazo had not asked Alexander Vasquez to pick up Joel Perez on August 5, 2008.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
14
COUNT THREE
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about August 27, 2009, at Chicago, in the Northern District of Illinois,
BEAU BRINDLEY
knowingly caused the making of a false material declaration under oath in the United States
District Court during the trial of United States v. Alexander Vasquez, Case Number 08-CR-625,
when BRINDLEY asked the following questions and Marina Collazo gave the following
answers:
Q.
Now, when Alexander Vasquez went to go and pick up Joel Perez, did you give
him the keys to the Bonneville right away when he left?
A.
No. He walked out and then walked back in and told me that I was blocking his
car.
Q.
A.
In the garage.
Q.
A.
Yes.
Q.
A.
In the back.
Q.
A.
Um-hum, yes.
Q.
A.
Q.
And then he come back inside because the car was blocking it?
A.
Yes.
15
Q.
And so when Mr. Vasquez came back inside, what did you do?
A.
Q.
A.
Yes.
Defendant BRINDLEY knew that this testimony was false because he knew Marina
Collazo had not given Alexander Vasquez keys to the Bonneville on August 5, 2008.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
16
COUNT FOUR
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about September 1, 2009, at Chicago, in the Northern District of Illinois,
BEAU BRINDLEY
knowingly caused the making of a false material declaration under oath in the United States
District Court during the trial of United States of America v. Alexander Vasquez, Case Number
08-CR-625, when BRINDLEY asked the following questions and Marina Collazo gave the
following answers:
Q.
And when I spoke to you about what you remembered about August 5th, I told
you that all I wanted you to do was tell us the truth about what happened. Thats
what I told you, isnt it?
*
Q.
*
Isnt it?
A.
Yes.
Q.
Lets get one thing straight. During all the meetings that I ever had with you,
Mrs. Perez, I never once told you what to say about anything, did I?
A.
Defendant BRINDLEY knew that this testimony was false because he had in fact planned
and agreed with Marina Collazo that Collazo would testify falsely about the events of August 5,
2008, based on fictitious information provided to Collazo by BRINDLEY.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
17
COUNT FIVE
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
Between in or around August 2009, and in or around September 2009, at Chicago, in the
Northern District of Illinois,
BEAU B. BRINDLEY
corruptly obstructed, influenced, and impeded an official proceeding, and attempted to do so,
namely, the trial of United States of America v. Alexander Vasquez, Case Number 08-CR-625, in
the United States District Court for the Northern District of Illinois, by knowingly presenting
false testimony.
In violation of Title 18, United States Code, Section 1512(c)(2).
18
COUNT SIX
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about December 7, 2010, at Chicago, in the Northern District of Illinois,
BEAU B. BRINDLEY and
MICHAEL THOMPSON
knowingly caused the making of a false material declaration under oath in the United States
District Court during the trial of United States of America v. Bennie Wilcox, Case Number
08-CR-256, when defendant BRINDLEY asked the following questions and Karilyn Wilcox
gave the following answers:
Q:
And what steps did you take to monitor his [Bennie Wilcoxs] e-mail during that
week before he - - you were going to be out of town?
A:
Defendants BRINDLEY and THOMPSON knew this testimony regarding Mary was
false because THOMPSON directed Karilyn Wilcox to testify falsely about giving a co-worker
access to Bennie Wilcoxs email account.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
19
COUNT SEVEN
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about December 7, 2010, at Chicago, in the Northern District of Illinois,
MICHAEL THOMPSON
knowingly made and caused the making of a false material declaration under oath in the United
States District Court during the trial of United States of America v. Bennie Wilcox, Case Number
08-CR-256, when Karilyn Wilcox gave the following answers during cross-examination:
Q:
A:
Q:
A:
I dont remember.
Defendant THOMPSON knew this testimony was false because THOMPSON directed
Karilyn Wilcox to testify that she gave a co-worker access to Bennie Wilcoxs email account;
and that the co-worker Wilcox named should no longer work at United Health Group.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
20
COUNT EIGHT
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about December 7, 2010, at Chicago, in the Northern District of Illinois,
BEAU B. BRINDLEY and
MICHAEL THOMPSON
knowingly caused the making of a false material declaration under oath in the United States
District Court during the trial of United States of America v. Bennie Wilcox, Case Number
08-CR-256, when defendant BRINDLEY asked the following questions and Karilyn Wilcox
gave the following answers:
Q:
All right. Now, you were asked questions about whether youve ever talked to
anyone about or told anyone about Mary checking for you with this e-mail in the - before today. Mrs. Wilcox, in fact, have you been interviewed by people
associated with the defense of your husband on multiple occasions prior to today?
A:
Yes
Q:
And during those previous interviews, had you disclosed that information before?
A:
Yes
Q:
Was the answer to that question, yes, you had disclosed this information to them
A:
Yes
Q:
- - before today?
Defendants BRINDLEY and THOMPSON knew this testimony was false because
Karilyn Wilcox had not disclosed information about Mary, prior to December 7, 2010, during
multiple prior interviews with people associated with the defense of Bennie Wilcox.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
21
COUNT NINE
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about December 7, 2010, at Chicago, in the Northern District of Illinois,
BEAU B. BRINDLEY and
MICHAEL THOMPSON
corruptly obstructed, influenced, and impeded an official proceeding, and attempted to do so,
namely, the trial of United States of America v. Bennie Wilcox, Case Number 08-CR-256, in the
United States District Court for the Northern District of Illinois, by knowingly presenting false
testimony.
In violation of Title 18, United States Code, Section 1512(c)(2).
22
COUNT TEN
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about December 15, 2011, and December 16, 2011, at Chicago, in the Northern
District of Illinois,
BEAU B. BRINDLEY
knowingly caused the making of a false material declaration under oath in the United States
District Court during the trial of United States of America v. Richard Harrington, Case Number
09-CR-814, when defendant BRINDLEY asked the following questions and Richard Harrington
gave the following answers:
Q.
When you say youre not guilty of this charge, can you explain what you
mean and why you say that?
A.
Q.
A.
No.
Q.
A.
No.
Q.
A.
No.
*
Q.
*
*
All right. But possessing this handgun, the .40-caliber Smith &Wesson
charged in this case, is that something that you ever did?
A.
No, it is not.
23
Q.
Okay. And was there ever any point in time when you purchased or
owned or possessed one of those guns, the .40 caliber Smith & Wesson?
A.
No.
Q.
Did you ever possess that firearm -- .40-caliber Smith & Wesson on
October 7th, 2009?
A.
Defendant BRINDLEY knew this testimony was false because BRINDLEY and Richard
Harrington planned and agreed that Harrington would testify falsely that Harrington had never
possessed the Smith and Wesson .40 caliber firearm.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
24
COUNT ELEVEN
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about December 15, 2011, and December 16, 2011, at Chicago, in the Northern
District of Illinois,
BEAU B. BRINDLEY
knowingly caused the making of a false material declaration under oath in the United States
District Court during the trial of United States of America v. Richard Harrington, Case Number
09-CR-814, when defendant BRINDLEY asked the following questions and Richard Harrington
gave the following answers:
Q.
That gun that was found in the car after your arrest, did you know that gun
was in the car?
A.
Q.
Okay. Now, when you left that night to go to meet Mingo and this
supplier, did you take any firearms with you?
A.
Q.
Okay.
A.
Q.
Did you know that there were any firearms in the car with you when you
got in to go meet with Mingo and the supplier?
A.
Q.
Did you have any firearms or know about any firearms in the car that night
[October 7, 2009]?
A.
Absolutely not.
25
Q.
And this particular handgun [Smith and Wesson .40 caliber firearm], did
you have any knowledge or any awareness that this gun was anywhere
near your GMC Denali on October the 7th 2009?
A.
No, I do not.
BRINDLEY knew this testimony was false because BRINDLEY and Richard Harrington
planned and agreed that Harrington would testify falsely that Harrington did not know that the
Smith and Wesson .40 caliber firearm was in Harringtons car on October 7, 2009.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
26
COUNT TWELVE
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about December 15, 2011, and December 16, 2011, at Chicago, in the Northern
District of Illinois,
BEAU B. BRINDLEY
knowingly caused the making of a false material declaration under oath in the United States
District Court during the trial of United States of America v. Richard Harrington, Case Number
09-CR-814, when defendant BRINDLEY asked the following questions and Richard Harrington
gave the following answers:
Q.
Okay. Now, were there guns that you did have to protect yourself and
your drug money?
A.
Q.
A.
Q.
Okay. Now, did you have other guns that you actually did use to protect
your drug proceeds?
A.
Yes.
Q:
A:
27
BRINDLEY knew this testimony was false because BRINDLEY and Richard Harrington
planned and agreed that Harrington would testify falsely that Harrington had not possessed the
Smith and Wesson .40 caliber firearm, as charged in Count Eighteen of United States of America
v. Richard Harrington, Case Number 09-CR-814, in furtherance of drug trafficking activities.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
28
COUNT THIRTEEN
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about December 15, 2011, and December 16, 2011, at Chicago, in the Northern
District of Illinois,
BEAU B. BRINDLEY
corruptly obstructed, influenced, and impeded an official proceeding, and attempted to do so,
namely, the trial of United States of America v. Richard Harrington, Case Number 09-CR-814,
in the United States District Court for the Northern District of Illinois, by knowingly presenting
false testimony.
In violation of Title 18, United States Code, Section 1512(c)(2).
29
COUNT FOURTEEN
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about August 21, 2012, at Chicago, in the Northern District of Illinois,
BEAU B. BRINDLEY
knowingly caused the making of a false material declaration under oath in the United States
District Court during the trial of United States of America v. Isaac Myles, Case Number
10-CR-647, when defendant BRINDLEY asked the following questions and Isaac Myles gave
the following answers:
Q:
Okay.
A:
Yes.
Q:
A:
Q:
A.
Q.
Can you explain why it is you bought the gun in November of 09?
A.
Q.
Okay. And when, approximately, did that happen where the garage was broken
into and the items were stolen that belonged to your mother?
A.
*
Q.
And what was the only purpose you had when you bought the gun?
30
A.
Defendant BRINDLEY knew this testimony was false because BRINDLEY and Isaac
Myles planned and agreed that Isaac Myles would testify falsely about when and why Myles
purchased the .22 caliber revolver.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
31
COUNT FIFTEEN
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about August 21, 2012, at Chicago, in the Northern District of Illinois,
BEAU B. BRINDLEY
knowingly made and caused the making of a false material declaration under oath in the United
States District Court during the trial of United States of America v. Isaac Myles, Case Number
10-CR-647, when defendant BRINDLEY asked the following questions and Isaac Myles gave
the following answers:
Q:
Now, when, if ever, did you take the firearm that you purchased from Will [.22
caliber firearm] to Lashon Finleys residence, where you mixed heroin?
A:
Never.
Q:
The firearm [.22 caliber revolver] that you purchased that you said for protection
at your moms house, what did you do with it after you bought it?
A:
Q:
And when if ever, did you take it out from under that mattress after that?
A:
*
Q:
*
*
When, if at any time, did you carry the .22-caliber handgun you purchased?
A:
Never.
Q:
Mr. Myles, the gun under the mattress, the .22-caliber gun, when, if ever, did you
use it in connection with any drug purchase, use, or sale?
A:
Never.
*
Q:
So what did the gun that you kept under your mattress have to do with
drug-dealing?
32
A:
Nothing.
Q:
When, if at any time, did you take it out at all when you had drugs, ever?
A:
Never.
Defendant BRINDLEY knew this testimony was false because BRINDLEY and Isaac
Myles planned and agreed that Isaac Myles would testify falsely about whether Myles used or
possessed the .22 caliber firearm in connection with drug trafficking activities.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
33
COUNT SIXTEEN
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about August 21, 2012, at Chicago, in the Northern District of Illinois,
BEAU B. BRINDLEY
corruptly obstructed, influenced, and impeded an official proceeding, and attempted to do so,
namely, the trial of United States of America v. Isaac Myles, Case Number 10-CR-647, in the
United States District Court for the Northern District of Illinois, by knowingly presenting false
testimony.
In violation of Title 18, United States Code, Section 1512(c)(2).
34
COUNT SEVENTEEN
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about February 4, 2013, at Chicago, in the Northern District of Illinois,
BEAU B. BRINDLEY
knowingly caused the making of a false material declaration under oath in the United States
District Court during the trial of United States of America v. Rahshone Burnett, Case Number
09-CR-1030, when defendant BRINDLEY asked the following questions and Richard
Harrington gave the following answers:
Q.
Okay. And when you sold him the 125 or 150 grams [of heroin], when
did he pay you for that?
A.
Q.
Did you ever wait at any time, whether it was 1 gram or 100 grams, did
you ever wait and let him go out and sell the product and pay you later?
Did you ever do that?
A.
*
No.
Q.
When Rahshone gave you money in terms of purchasing heroin, what was
that money for? When he handed you the money, what was it for?
A.
Q.
And after he gave you the money, is that when he received the heroin?
A.
Yes, it is.
Q.
Okay . . . was there ever a time where you gave him heroin before, where
you gave him heroin before he gave you money?
A.
No.
35
Defendant BRINDLEY knew this testimony was false because BRINDLEY and Richard
Harrington planned and agreed that Harrington would testify falsely that Harrington never gave
heroin to Rahshone Burnett before Burnett paid for the heroin.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
36
COUNT EIGHTEEN
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about February 5, 2013, at Chicago, in the Northern District of Illinois,
BEAU B. BRINDLEY
knowingly caused the making of a false material declaration under oath in the United States
District Court during the trial of United States of America v. Rahshone Burnett, Case Number
09-CR-1030, when defendant BRINDLEY asked the following questions and Richard
Harrington gave the following answers:
Q.
Okay . . . did Rahshone Burnett ever agree to combining his money with
yours for the purpose of getting heroin at a cheaper price?
A.
Q.
When, if at any time, did you allow him to get a lower price because you
put his money with yours? When did that ever happen?
A.
Defendant BRINDLEY knew this testimony was false because BRINDLEY and Richard
Harrington planned and agreed that Harrington would testify falsely that Harrington and
Rahshone Burnett never pooled their money to buy heroin.
In violation of Title 18, United States Code, Sections 1623(a) and 2.
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COUNT NINETEEN
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about February 4, 2013, and February 5, 2013, at Chicago, in the Northern District
of Illinois,
BEAU B. BRINDLEY
corruptly obstructed, influenced, and impeded an official proceeding, and attempted to do so,
namely, the trial of United States of America v. Rahshone Burnett, Case Number 09-CR-1030, in
the United States District Court for the Northern District of Illinois, by knowingly presenting
false testimony.
In violation of Title 18, United States Code, Section 1512(c)(2).
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COUNT TWENTY
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
1.
corruptly obstructed, influenced, and impeded an official proceeding, and attempted to do so,
namely, case United States of America v. David Conrad, Case Number 05-CR-931, in the United
States District Court for the Northern District of Illinois, by filing a document with the court,
titled Status Report, which defendants knew contained false information about the physical
manifestations of illness that David Conrad exhibited on April 7, 2010.
2.
In the Status Report, BRINDLEY and THOMPSON falsely stated the following
with respect to the physical manifestations of illness that David Conrad exhibited during the
meeting between BRINDLEY and Conrad on April 7, 2010: (a) Mr. Conrad was sweating
profusely during the meeting; (b) His hands shook violently; and (c) The meeting was twice
interrupted by Mr. Conrad leaving the room to vomit.
In violation of Title 18, United States Code, Sections 1512(c)(2) and 2.
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COUNT TWENTY-ONE
The SPECIAL FEBRUARY 2014 GRAND JURY further charges:
On or about October 23, 2012, at Chicago, in the Northern District of Illinois,
BEAU B. BRINDLEY and
MICHAEL THOMPSON
corruptly obstructed, influenced, and impeded an official proceeding, and attempted to do so,
namely, a federal grand jury investigation in the Northern District of Illinois, by falsely asserting
to the United States Attorneys Office for the Northern District of Illinois that (a) MICHAEL
THOMPSON was retained to represent grand jury witness Individual A; and (b) Individual A
would assert her Fifth Amendment rights and decline to answer any substantive questions if
called before the grand jury, knowing that THOMPSON did not represent Individual A and that
Individual A did not intend to assert her privilege against self-incrimination.
In violation of Title 18, United States Code, Sections 1512(c)(2) and 2.
A TRUE BILL:
FOREPERSON
Date:
MICHAEL J. CHMELAR
MEL S. JOHNSON
Special Attorneys to the
United States Attorney General
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