Back to Washington Teachers Union main page
|
Major Areas Calendars Columns Directories |
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA V. ERROL ALDERMAN, Defendant. CRIMINAL No.: 18 U.S.C. § 371 (Conspiracy) INFORMATIONThe United States Attorney charges that: COUNT ONE (Conspiracy)At all times material to the Information: 1. The Washington Teachers' Union ("WTU" or "the union") was a labor organization representing, among other persons, teachers in the District of Columbia Public School system, and was the Washington, D.C. local affiliate of the American Federation of Teachers ("AFT"). WTU received most of its funds from dues collected from the paychecks of its schoolteacher members. 2. WTU was a labor organization under the oversight of the United States Department of Labor ("DOL") and was required annually to submit reports of its financial condition ("Forms LM-2") to DOL. 3. WTU's operations were overseen, or should have been overseen, officers and employees, including but not limited to the persons occupying the offices of WTU President, WTU General Vice-President, and WTU Treasurer. For all periods relevant to this Information, the persons occupying these offices did not change. 4. WTU President was a full-time, salaried official of WTU. WTU Treasurer was at various times a full-time, salaried official of WTU. 5. WTU President was assisted in his/her job by Executive Assistant, who was WTU's office manager and, at times, legislative representative from the WTU to the Government of the District of Columbia. 6. WTU checks were required to be signed by two of the three persons occupying the positions of WTU President, WTU General Vice-President, and WTU Treasurer. WTU President also delegated to Executive Assistant authority to affix a stamp of WTU President's signature to WTU checks. Executive Assistant did, in fact, write many WTU checks, affix WTU President's signature stamp, and obtain WTU Treasurer's actual signature. 7. Defendant ERROL ALDERMAN was a friend of Michael Martin, who was Executive Assistant's son-in-law. Defendant ERROL ALDERMAN had no legitimate business relationship with WTU, its officers, or its employees. THE CONSPIRACY8. From in or about. July 1998, the exact date being unknown, through in or about October 2002, within the District of Columbia and elsewhere, defendant ERROL ALDERMAN did unlawfully, willfully, and knowingly conspire, confederate, and agree, together with others known and unknown, to commit offenses against the United States, to wit:
in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i); and
THE GOAL OF THE CONSPIRACY9. It was the goal of the conspiracy for the conspirators to enrich themselves by stealing money from WTU and its members and to secrete their unlawful conduct by engaging in financial transactions designed to conceal and hide the unlawful derivation of these funds. MANNER AND MEANS OF THE CONSPIRACY10. It was a part of the conspiracy that WTU President, WTU Treasurer, and Executive Assistant embezzled and stole more than $2.5 million in WTU's assets by obtaining cash withdrawn unlawfully from the WTU bank account, writing WTU checks to themselves, and using WTU credit cards to acquire luxury clothing, electronic equipment, season tickets for professional sports events, meals and other entertainment, home furnishings, art, gasoline and repairs for their personal vehicles, and other items. 11. It was further a part of the conspiracy that WTU President, WTU Treasurer, and Executive Assistant would write checks to defendant ERROL ALDERMAN, Michael Martin, and others so that the checks could be cashed and the money returned to WTU President and Executive Assistant and be used by them to pay WTU credit card bills. 12. It was further a part of the conspiracy that defendant ERROL ALDERMAN opened an account at a federally-insured financial institution in the name of a fictitious business association called "Expressions Unlimited," which was controlled and used by defendant ERROL ALDERMAN, Michael Martin, and Michael Martin's wife (Executive Assistant's daughter). Defendant ERROL ALDERMAN was the sole authorized signatory for this account. 13. It was further apart of the conspiracy that the purpose of the "Expressions Unlimited" account was to launder WTU funds in a manner directed by WTU President and Executive Assistant, including concealing the embezzlement of union funds, by making it appear that expenditures of WTU funds for personal purposes had been reimbursed by WTU President. 14. It was further a part of the conspiracy that WTU President, WTU Treasurer, and Executive Assistant would and did write WTU checks for several thousand dollars at a time, ultimately totaling $483,543.21, to Expressions Unlimited. 15. It was further a part of the conspiracy that Michael Martin would receive direction from Executive Assistant and/or WTU President as to how much money to withdraw from the Expressions Unlimited account and how to distribute the proceeds, including but not limited to cashing checks and distributing cash to Executive Assistant and WTU President or writing checks drawn on the Expressions Unlimited account and depositing such checks into accounts controlled by Executive Assistant and WTU President. Michael Martin, in turn, would sometimes instruct defendant ERROL ALDERMAN about how much money to withdraw from the Expressions Unlimited account. 16. It was further a part of the conspiracy that defendant ERROL ALDERMAN, aided and abetted by Michael Martin and others known and unknown, would and did deposit and cause to be deposited WTU checks into the Expressions Unlimited account and give some or all of the proceeds back to Executive Assistant and WTU President, generally channeling the funds through Michael Martin. 17. It was further a part of the conspiracy that WTU President, WTU Treasurer, and Executive Assistant concealed, and sought to conceal, the payment of funds to defendant ERROL ALDERMAN and Expressions Unlimited by creating and causing the creation of false, fictitious, and fraudulent WTU payment vouchers to support checks written to Expressions Unlimited. 18. It was further a part of the conspiracy that the conspirators sought to conceal and cover up their embezzlement and laundering of criminal proceeds by creating false, fictitious, and fraudulent Expressions Unlimited "invoices" for submission to auditors of WTU retained by AFT. 19. It was further a part of the conspiracy that defendant ERROL ALDERMAN would keep some of the money deposited into the Expressions Unlimited account through his use of a debit bank card drawn on the Expressions Unlimited account. 20. It was further a part of the conspiracy that defendant ERROL ALDERMAN participated, and continued to participate, in the conspiracy because he was receiving assistance in securing employment with the Government of the District of Columbia from Michael Martin. OVERT ACTS21. In furtherance of the goal and objects of the conspiracy, defendant ERROL ALDERMAN and his co-conspirators, known and unknown, within the District of Columbia, engaged in the following overt acts, among many others:
(Conspiracy, in violation of Title 18, United States Code, Section 371). ROSCOE C. HOWARD, JR. BY: JAMES W. COOPER |
Send mail with questions or comments to webmaster@dcpswatch.com
Web site copyright ©1997-2003, DCWatch