1. Defendant BARBARA A. BULLOCK was from in or about 1994 until in or about September 2002 the president of the Washington Teachers' Union Local 6 ("WTU"), American Federation of Teachers ("AFT"), AFL-CIO, and was responsible for the administration of all of the affairs of WTU. WTU had other elected officers and employees, including, but not limited to an elected general vice president ("WTU Vice President") and an elected treasurer ("WTU Treasurer").

2. In or about 1996, defendant BARBARA A. BULLOCK hired Executive Assistant as a full-time, salaried employee of WTU. From the time of her hire until in or about September 2002,.Executive Assistant served as defendant BARBARA A. BULLOCK'S assistant, as WTU office manager, and at times, as WTU's legislative representative to the Government of the District of Columbia.

3. WTU was a labor organization within the meaning of the Labor Management Reporting and Disclosure Act of 1959 and, as such, was regulated by the United States Department of Labor ("DOL"). WTU's activities affected interstate commerce because, among other reasons, certain of its members were employed by the private sector entity National Child Day Care Association ("NCDCA"), now known as Nation's Capital Child and Family Development. In addition to representing the NCDCA employees, WTU was the collective bargaining unit for approximately 5,000 teachers and retired professionals of the District of Columbia Public School system ("DCPS").

4. As a labor organization regulated by DOL, WTU was required annually to submit a financial disclosure report to IDOL known as Form LM-2. Form LM-2 required disclosure of, among other things, disclosure of a labor organization's revenues and expenditures, including expenditures to or for the benefit of officers and employees, payment of dues to parent organizations, and payments to employee pension plans.

5. WTU, which was a federal tax-exempt organization, received most of its funds from dues collected from the paychecks of its schoolteacher members. Because DCPS teachers who were not members of WTU received salary increases and other benefits negotiated by WTU, the District of Columbia. Office of Pay and Retirement also deducted from the paychecks of non-WTU member DCPS teachers a fee, known as an agency fee, as a substitute for dues.

6. WTU's financial affairs were overseen, or should have been overseen, by its officers and employees, including, but not limited-to, defendant BARBARA A. BULLOCK, who occupied a position of trust in relation to WTU and its individual members and who, therefore, owed a fiduciary duty to hold the money and property of WTU solely for the benefit of WTU and its members and to manage, invest, and expend the money and property of WTU for official union purposes, and not for the personal benefit of the officers and employees, their friends, and their relatives.

7. The United States Internal Revenue Service ("IRS") required tax-exempt labor organizations to file federal tax returns known as Forms 990 each year- Forms 990 called for, among other information, disclosure of compensation of officers and employees, as well as an accounting of the organization's receipts and expenditures of funds for other purposes. Federal law required that filers of Forms 990 maintain copies of completed Forms 990 for three years within their office space for inspection by the public.

8. Forms 990 called for the signature of an officer. Above the signature lines of the Form 990 was the following: "Under penalties of perjury, I declare that I have examined the return, including accompanying schedules and statements, and. to the best of my knowledge and belief, it is true, correct, and complete."

The Scheme

9. Beginning in or about November 1995 and continuing through in or about October 2002, in the District of Columbia and elsewhere, defendant BARBARA A. BULLOCK, aided and abetted by others known and unknown, knowingly and willfully did devise and intend to devise a scheme and artifice to defraud WTU and its individual members and to obtain their money and property by means of materially false and fraudulent pretenses, representations, and promises.

Purpose of the Scheme

10. It was the purpose of the scheme for defendant BARBARA A. BULLOCK, WTU Treasurer, and Executive Assistant to enrich themselves and others by stealing millions of dollars from WTU and its individual members, and to hide and cover up the scheme, its objects, and the actions taken in furtherance of it.

Manner and Means of the Scheme

11. It was a part of the scheme that defendant BARBARA A. BULLOCK, aided and abetted by others known and unknown, would and did steal, embezzle, and convert well over $2.S million from WTU and its individual members, and conceal and cover up the scheme; in the following ways, among others:

a. causing WTU to pay for personal expenditures of defendant BARBARA A. BULLOCK, WTU Treasurer, and Executive Assistant, for clothing, meals, travel, entertainment, art, vehicle repairs and maintenance, jewelry, professional sports season tickets, electronic equipment, silver, custom wigs, dental implants, limousine service, personal catering, and other luxury items, which they charged to WTU credit cards and personal credit cards;

b. diverting hundreds of thousands of dollars to herself and others by writing and causing the writing of WTU checks to intermediaries who laundered the funds and shared with them the proceeds;

c. writing and causing the writing of checks to herself, as well as WTU Treasurer and Executive Assistant, and stating falsely that the checks were to pay for, among other things, "special projects," "professional Services," and "expense reimbursements"; and

d. fraudulently instructing the District of Columbia Office of Pay and Retirement in one pay period to withhold from each DCPS teacher's paycheck $144 more than the lawful WTU dues deduction and to remit the funds ($826,842.90, of which at least $720,000 was withheld improperly) to the union to be stolen by defendant BARBARA A. BULLOCK, WTU Treasurer, Executive Assistant, and others.

12 . It was further a part of the scheme that defendant BARBARA A. BULLOCK, aided and abetted by others known and unknown, would and did sometimes use WTU funds laundered through third parties to make it appear that she was reimbursing WTU for personal credit card charges or paying personal credit card charges herself.

13. It was further a part of the scheme that defendant BARBARA A. BULLOCK, aided and abetted by others known and unknown, did prepare and cause the preparation of false reports about WTU's financial condition, including false Forms 990 filed with the IRS, false Forms LM-2 filed with DOL, false quarterly financial reports presented to WTU's Board of Trustees, and false budget data presented to WTU's Executive Board and general membership.

14 . It was further apart of the scheme that WTU retained the services of accountants who assisted defendant BARBARA A. BULLOCK and others in concealing their embezzlement of funds in official reports of WTU's finances, including Forms 990, LM-2, and quarterly financial reports.

Use of the Mails in Execution of the Scheme

15. On or about April 18, 2002, in the District of Columbia, defendant BARBARA A. BULLOCK, aided and abetted by others known and unknown, for the purpose of executing the above-described scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations, and promises, and attempting to do so, did place in any United States post office and authorized depository for mail matter, any matter and thing whatever, to be sent and delivered by the United States Postal Service, to wit: a letter directing the District of Columbia Office of Pay and Retirement to withhold $160.09 from each teacher's paycheck as union dues.

(Mail Fraud, and Aiding and Abetting and Causing an Act to Be Done, in violation of Title 18, United States Code, Sections 1341 & 2).

COUNT TWO (Conspiracy)

16. The allegations of Paragraph I through 8 of the Information are re-alleged as though fully set forth herein.

17. Beginning in or about 1996 continuing through in or about October 2002, in the District of Columbia and elsewhere, defendant BARBARA A. BULLOCK did knowingly combine, conspire, confederate, and agree together with others known and unknown to commit offenses against the United States, to wit:

a. to embezzle, steal, and convert to their own use and the use of another the money and property of a labor organization, to wit: the WTU, of which defendant BARBARA A. BULLOCK was an officer and was employed, in violation of Title 29, United States Code, Section 501(c); and

b. willfully to aid and assist in, and procure, counsel, and advise the preparation and presentation under, and in connection with any matter arising under, the internal revenue laws, Forms 990, which were false as to material matters and were fraudulent, in violation of Title 26, United States Code, Section 7206(2).

Purpose of the Conspiracy

18. It was the purpose of the conspiracy for defendant BARBARA A. BULLOCK, WTU Treasurer, and Executive Assistant to enrich themselves and others by stealing millions of dollars from WTU and its individual members, and to bide and cover up the conspiracy, its objects, and the actions taken in furtherance of it.

Overt Acts

19. In furtherance of the conspiracy and to achieve and carry out its unlawful objectives, defendant BARBARA A. BULLOCK, aided and abetted by her co-conspirators known and unknown, did commit the following overt acts, among many others, in the District of Columbia:

a. On or about August 21, 2001, Executive Assistant wrote a WTU check in the amount of $96,459.57 to American Express to pay for personal credit card charges of defendant BARBARA A. BULLOCK and others known and unknown.

b. On or about January 31, 2002, Executive Assistant mailed IRS Form 990 for WTU Fiscal Year 2001, which contained false and fraudulent categorizations of personal credit card charges and payments by check to BULLOCK, WTU Treasurer, and Executive Assistant as legitimate WTU expenditures, to the IRS in Philadelphia, Pennsylvania.

c. On or about February 10, 2002, WTU Treasurer gave a false and fraudulent report of WTU's revenues and expenditures for the quarter October 1, 2001, through December 31, 2001, to the WTU Board of Trustees, among other things, deliberately slashing the actual amount of revenues and expenses by over $400,000 and falsely describing the uses of union funds during the quarter.

d. On or about April 17, 2002, WTU Treasurer drafted a letter instructing the District of Columbia Office of Pay and Retirement to withhold $144 more than the lawful WTU dues deduction.

e. From or about June 14 through. 20, 2002, defendant BARBARA A. BULLOCK wrote and caused to be written from the proceeds of the improper teaches: dues deduction, among other WTU checks, WTU checks in the amounts of $388,083.42 to AFT; $14,416.86 to defendant BARBARA A. BULLOCK (over and above payroll); $18,805.02 to Executive Assistant (over and above payroll); $28,939.22 to WTU Treasurer; and $10,000 to defendant BARBARA A. BULLOCK's sister's Diners Club credit card account.

(Conspiracy, in violation of Title 18, United States Code, Section 371).

ROSCOE C. HOWARD, JR.
ATTORNEY FOR THE UNITED STATES IN AND FOR THE DISTRICT OF COLUMBIA

By:
JAMES W. COOPER
ANTHONY M. ALEXIS
ASSISTANT UNITED STATES ATTORNEYS

Barbara Bullock, Criminal information in Washington Teachers Union Embezzlement October 3, 2003

COUNT ONE (Mail Fraud)