No Easy Answers
Monday, August 04, 2008
Senator Stevens Indictment - July 29, 2008
Case 1:08-cr-00231-EGS Document 1 Filed 07/29/2008 Page 1 of 28
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA, ) GRAND JURY ORIGINAL
)
v. ) Criminal No.
)
THEODORE F. STEVENS, ) COUNTS ONE: 18 U.S.C. � 1001
) THROUGH SEVEN: (False Statements)
Defendant. )
)
)
INDICTMENT
THE GRAND JURY CHARGES THAT:
Unless specified otherwise, at all times relevant to this Indictment:
COUNT ONE
FALSE STATEMENTS
(18 U.S.C. � 1001(a)(1))
I. BACKGROUND
A. Relevant Parties and Entities
1. THEODORE F. STEVENS (hereinafter "STEVENS") was an elected member of
the United States Senate. STEVENS has represented the State of Alaska in the United States
Senate since 1968. From 1997 to 2001 and from 2003 to 2005, STEVENS was chairperson of
the Senate Committee on Appropriations, which was responsible for the drafting of legislation to
allocate federal funds to numerous government agencies, departments, and organizations on an
annual basis.
2. The "Girdwood Residence" was a piece of real estate, including a single-family
house, located in Girdwood, Alaska. The Girdwood Residence was owned by STEVENS and his
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wife. STEVENS often referred to the Girdwood Residence as "the chalet."
VECO Corporation (hereinafter "VECO") was a privately held, Alaska-based
corporation that, among other things, provided oil pipeline and construction services to the oil
industry and to the public sector worldwide. VECO was one of the largest private employers in
Alaska, with multiple subsidiary companies and more than 4,000 employees internationally.
VECO was not in the business of home construction, remodeling, or improvement.
4. BILL J. ALLEN (hereinafter "ALLEN") was the Chief Executive Officer and
part-owner of VECO. ALLEN was a personal friend of STEVENS.
5. PERSON A was the owner of a retail business located in the State of Alaska.
PERSON A was a personal friend of STEVENS.
6. PERSON B was the owner of a real estate business located in the State of Alaska.
PERSON B was a personal friend of STEVENS.
7. Construction Firm A was a private residential construction firm located in the
State of Alaska.
B. The United States Senate's Financial Disclosure Forms
8. Recognizing that public office is a public trust, Congress enacted the Ethics in
Government Act of 1978 ("EIGA") in part to restore public confidence in its institutions. EIGA
requires all members of the United States Senate to file a form by May of the following year,
detailing specified financial transactions that the Member engaged in during the prior calendar
year (hereinafter a "Financial Disclosure Form"). These Financial Disclosure Forms were
documents required to be submitted to and filed with the Secretary of the United States Senate
(hereinafter "Secretary of the Senate"), an office within the legislative branch, and were available
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to the public.
9. A primary purpose of the yearly Financial Disclosure Forms is to disclose,
monitor and deter conflicts of interest, thereby maintaining public confidence in the integrity of
the United States Senate and its Members. Because the yearly Financial Disclosure Forms
require public disclosure of financial information by each Member of the United States Senate,
such as income, assets, gifts, financial interests, and liabilities, the Forms provide the public at
large, including the voters of a particular state, with the information necessary to allow the public
to evaluate and consider official conduct by a Member of the United States Senate in light of that
Member's private finances.
10. The Secretary of the Senate was an office or agency of the United States Congress
that was responsible for receiving the Financial Disclosure Forms filed by, or on behalf of, each
United States Senator, and for providing accurate information to the public about the financial
disclosures filed by, or on behalf of, each United States Senator. The Financial Disclosure Forms
were subject to further review and possible investigation by the United States Senate Select
Committee on Ethics.
11. For calendar years 1999 through 2006, the Financial Disclosure Forms contained a
section that read as follows: "Any individual who knowingly and willfully falsifies . . . this
report may be subject to civil and criminal sanctions. (See 5 U.S.C. app. 6, 104, and 18 U.S.C.
1001.)" This section was located next to the signature block on the first page of each Financial
Disclosure Form.
12. For calendar years 1999 through 2006, the Financial Disclosure Forms required
the filer to disclose certain particular information concerning income, assets, liabilities, and
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outside positions either held or obtained by himself, his spouse, and any dependent children
during that calendar year.
13. With respect to liabilities, the Financial Disclosure Forms required the filer to
disclose the amount of liabilities in excess of $10,000 that were owed at any point in time during
that calendar year by the filer, the filer's spouse, or any dependent child, as well as the identity of
the individual or entity to whom each debt was owed.
14. With respect to gifts, the Financial Disclosure Forms also required the filer to
disclose gifts received by himself, his spouse, and any dependent children during that calendar
year. Each Form required the disclosure of gifts from a single source if the aggregate value of
the items received in that year was greater than a particular dollar value. For calendar years 1999
through 2002, that dollar value was $260; for calendar year 2003, it was $285; for calendar years
2004 through 2006, it was $305.
IL STEVENS' Scheme To Conceal His Receipt of Things of Value From ALLEN and
VECO.
15. Beginning in or about May 1999, and continuing to in or about August, 2007, in
the District of Columbia and elsewhere, in a matter within the jurisdiction of the legislative
branch of the United States Government and subject to the legislative function exception,
STEVENS, while a sitting United States Senator, knowingly and willfully engaged in a scheme
to conceal a material fact, that is, his continuing receipt of hundreds of thousands of dollars'
worth of things of value from a private corporation and its chief executive officer by, among
other things, failing to report them, as was required, on STEVENS' required yearly Financial
Disclosure Forms. These things of value provided by ALLEN and VECO to STEVENS
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included, among other things: home improvements to the Girdwood Residence, such as the
creation of a new first floor, a new garage, a new first- and second-story wraparound deck, new
plumbing, new electrical wiring, and other such additions and improvements; automobile
exchanges in which STEVENS received new vehicles worth far more than the used vehicles
STEVENS provided in exchange; other household goods, such as furniture, a new, permanently-
attached professional Viking gas grill, and a new multi-drawer, stationary tool storage cabinet
with new tools. The aggregate value of these things of value that STEVENS accepted was
greater than $250,000.
16. It was a further part of the scheme that STEVENS took multiple steps to conceal
his continued receipt of things of value from ALLEN and VECO. During the nearly seven-year
period in which STEVENS received multiple things of value from ALLEN and VECO,
STEVENS filed and caused to be filed false annual Financial Disclosure Forms for the years
1999 to 2006 that did not report STEVENS' receipt of any thing of value from ALLEN and
VECO, either as gifts or as liabilities, as required. STEVENS also made and caused to be made
multiple false representations to his friends, his staff, and the media concerning the
improvements at the Girdwood Residence and STEVENS' receipt of things of value from
ALLEN and VECO.
17. It was a part of the scheme that STEVENS, while during that same time period
that he was concealing his continuing receipt of things of value from ALLEN and VECO from
1999 to 2006, received and accepted solicitations for multiple official actions from ALLEN and
other VECO employees, and knowing that STEVENS could and did use his official position and
his office on behalf of VECO during that same time period. These solicitations for official
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action, some of which were made directly to STEVENS, included the following topics: (a)
funding requests and other assistance with certain international VECO projects and partnerships,
including those in Pakistan and Russia; (b) requests for multiple federal grants and contracts to
benefit VECO, its subsidiaries, and its business partners, including grants from the National
Science Foundation to a VECO subsidiary; and (c) assistance on both federal and state issues in
connection with the effort to construct a natural gas pipeline from Alaska's North Slope Region.
A. Things of Value from ALLEN and VECO to Benefit STEVENS
1999: A New 1999 Land Rover Discovery
18. In or about the spring of 1999, STEVENS and ALLEN discussed the fact that
STEVENS wished to obtain a new car for his dependent child. Thereafter, in or about June,
1999, ALLEN transferred a new 1999 Land Rover Discovery, which ALLEN had purchased new
for approximately $44,000, to STEVENS in exchange for STEVENS' 1964� Ford Mustang and
$5,000. At the time ALLEN transferred the 1999 Land Rover Discovery to STEVENS, the
1964� Ford Mustang was worth less than $20,000.
2000-2006: Improvements to the Girdwood Residence by VECO
19. Beginning in the spring and summer of 2000, STEVENS and ALLEN discussed
whether VECO could renovate the Girdwood Residence. After that conversation, spanning over
the next approximately six years, STEVENS accepted from ALLEN and VECO more than
$250,000 in free labor, materials, and other things of value in connection with the substantial
renovation, improvement, repair and maintenance to the Girdwood Residence. STEVENS never
paid ALLEN or VECO anything for these expenses, and STEVENS never listed his receipt of
these things of value on any of his yearly Financial Disclosure Forms, all the while sitting as one
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of Alaska's United States Senators.
2000-200]: Improvements to the Girdwood Residence
20. In or about the spring and summer of 2000, after STEVENS and ALLEN
discussed whether VECO could perform renovations on the Girdwood Residence, STEVENS
and ALLEN met with an architect employed by VECO to discuss the renovations of the
Girdwood Residence. Over the remainder of 2000, STEVENS expanded the scope of the project
so that the project eventually became a full basement, first-floor addition with multiple bedrooms
and a bathroom. The VECO architect prepared drawings for the proposed renovations and
discussed the drawings with STEVENS.
21. In or about the fall of 2000, VECO and STEVENS hired Construction Firm A to
perform a portion of the renovations at the Girdwood Residence. Construction Firm A's invoices
were sent to STEVENS, which STEVENS paid by personal check. Construction Firm A's
invoices, however, did not include the labor costs of VECO employees and contractors and did
not include the costs of materials provided by VECO.
22. Because VECO and STEVENS hired Construction Firm A to focus on the
carpentry and finish work of the renovations at the Girdwood Residence, VECO employees and
contractors performed a significant portion of the remaining renovations. ALLEN and others at
VECO directed VECO employees and contractors to perform the renovation tasks on the
Girdwood Residence.
23. From in or about June 2000 to in or about April 2001, multiple VECO employees
and contractors participated in renovating the Girdwood Residence. That renovation work
included jacking up and resting the house on stilts, building a new first floor with two bedrooms
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and a bathroom, renovating the existing residence, and adding a garage with workshop and a
second-story wraparound deck. Among other tasks, VECO employees and contractors also
installed electrical, plumbing, framing, heating, and flooring materials in the Girdwood
Residence. VECO employees and contractors also purchased and installed certain fixtures and
appliances.
24. From in or about the summer of 2000 to on or about December 31, 2001, VECO
incurred over $200,000 in materials, labor and other costs in connection with the work that
VECO employees and contractors performed at the Girdwood Residence. These costs included,
but were not limited to, approximately $81,775.18 in materials, labor, architectural design and
services, and other costs from approximately June 2000 to December 31, 2000, and
approximately $110,153.64 in the first three and a half months of 2001 alone.
25. STEVENS knew that VECO employees and contractors performed significant
portions of the Girdwood Residence renovations during calendar years 2000 and 2001.
Nonetheless, STEVENS never paid or reimbursed VECO at any time for the cost of materials
provided and labor performed by VECO and its employees and contractors on the Girdwood
Residence renovations during 2000 or 2001.
2002: Improvements to the Girdwood Residence by VECO
26. From in or about January 2002 to in or about December 2002, multiple VECO
employees and contractors continued to be involved in renovating, repairing, and improving the
Girdwood Residence. During calendar year 2002, the work performed by VECO employees and
contractors at the Girdwood Residence included, among other projects, the installation of a first-
floor wraparound deck, a plastic roof between the first- and second-floor decks, a heat tape
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system on the roof of the Girdwood Residence, and the installation and partial removal of rope
lighting on multiple portions of the property. These projects cost VECO approximately $55,000.
27. STEVENS knew that VECO employees and contractors performed significant
renovation tasks on the Girdwood Residence during calendar year 2002. Nonetheless,
STEVENS never paid or reimbursed VECO at any time for the cost of materials provided and
labor performed by VECO and its employees on the Girdwood Residence during calendar year
2002.
2004-2005: Improvements to the Girdwood Residence by VECO
28. From in or about July 2004 to on or about December 31, 2004, STEVENS
contacted ALLEN and VECO employees multiple times to request that VECO employees or
contractors perform additional tasks at the Girdwood Residence. These tasks included, without
limitation, the installation of multiple kitchen appliances and maintenance on the heat tape
system on the roof of the Girdwood Residence.
29. From in or about January 2005 to in or about December 2005, STEVENS
contacted ALLEN and VECO employees multiple times to request that VECO employees or
contractors perform additional tasks at the Girdwood Residence. These tasks included, without
limitation, roof and gutter repairs, electrical wiring, and the replacement of sensors.
30. STEVENS knew that VECO employees and contractors performed tasks at his
request on the Girdwood Residence during calendar years 2004 and 2005. STEVENS, however,
never paid or reimbursed VECO at any time for the cost of materials provided and labor
performed by VECO and its employees at the Girdwood Residence during those times.
31. The repairs performed by VECO employees or contractors at the Girdwood
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Residence in each of the calendar years 2004 and 2005 had a combined value of greater than
$305 for each of those two years.
2006: Improvements to the Girdwood Residence by VECO
32. In or about January, 2006, STEVENS contacted ALLEN to request that VECO
employees or contractors inspect and repair the boiler and heating system at the Girdwood
Residence.
33. On or about January 10, 2006, ALLEN contacted a VECO employee by telephone
and directed the VECO employee to travel to the Girdwood Residence to inspect and repair the
boiler and heating system. When the VECO employee arrived at the Girdwood Residence, both
STEVENS and ALLEN were there. Over the course of the next several days, the VECO
employee and an outside contractor performed the repairs to the boiler and heating system that
had been originally identified by STEVENS.
34. On or about January 25, 2006, ALLEN contacted the outside contractor referenced
in Paragraph 33 and directed him to split the repair costs into two invoices - one for materials
and one for labor - and to send the invoice for materials to STEVENS and the invoice for labor
to ALLEN. Each of those invoices was for an amount greater than $1,000. The invoice for
materials in fact was addressed to STEVENS in Washington, D.C., and was paid by STEVENS,
and the invoice for labor was addressed to ALLEN in Alaska and paid by ALLEN.
35. On or about February 16, 2006, after becoming aware that ALLEN had paid for
the labor costs for the boiler and heating system repairs at the Girdwood Residence, STEVENS
sent ALLEN an e-mail concerning the boiler and heating system repairs. Although STEVENS
now knew that ALLEN paid for the labor costs, and now knew the name and contact information
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of the outside contractor who had performed the work, STEVENS asked ALLEN to have the
outside contractor send STEVENS an invoice for the labor costs.
36. Despite this knowledge, STEVENS never reimbursed ALLEN for the labor costs
paid by ALLEN. STEVENS also never paid the outside contractor directly for the labor costs
paid by ALLEN.
B. STEVENS' Involvement in the Renovations
37. During the approximate six-year period in which VECO employees and
contractors were performing improvements and repairs to the Girdwood Residence, STEVENS
had repeated involvement and contact with the work being done by VECO. STEVENS'
involvement included, but was not limited to, the following:
STEVENS had multiple conversations and correspondence with ALLEN
in which the two discussed, among other things, the work of VECO
employees and contractors on the renovation project;
b. STEVENS interacted, in person and by telephone, with VECO employees
and contractors in both the planning and construction phases of the
improvements to the Girdwood Residence;
STEVENS was present at the Girdwood Residence when VECO
employees and contractors performed improvements and repairs to the
Girdwood Residence;
d. STEVENS reviewed and commented upon plans drawn by a VECO
employee, surveyed the work done by VECO employees and contractors
during the renovations, and at various times suggested additional
improvements be done by VECO employees and contractors;
e. STEVENS also thanked ALLEN multiple times for the work that VECO
and its employees and contractors had performed, and were performing, in
connection with the renovation of the Girdwood Residence.
38. For instance, on or about September 24, 2000, STEVENS sent an electronic mail
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("e-mail") to ALLEN that stated: "we've never worked with a man so easy to get along with as
[name of a VECO employee], Plus, everyone who's seen the place wants to know who has done
the things he's done. . . . You and [PERSON A] have been the spark plugs and we are really
pleased with all you have done. hope to see you and the chalet soon. best teds."
39. From in or about June 2000 to on or about August 30, 2006, PERSON A
monitored the work being done at the Girdwood Residence, and provided STEVENS with
periodic updates by e-mail on the renovations. In some of these communications, PERSON A
specifically noted that certain renovations were being done by VECO employees and contractors
at the direction of ALLEN.
40. For example, on or about October 7, 2002, PERSON A sent STEVENS an email
captioned "The House" in which PERSON A reported, among other things, that he "went by the
house [Girdwood Residence] on Friday and all is well, the downstairs deck w/cover is in place,
has been painted and looks great. . . We have a system for the de-icer that can't be mistaken.
Spoke to Bill about your concerns and all is well."
41. From in or about June 2000 to in or about February 2006, STEVENS was present
at the Girdwood Residence on multiple different occasions in which VECO employees and
contractors were performing renovation, repair or maintenance tasks at the Girdwood Residence.
On those occasions, STEVENS interacted with the VECO employees and contractors who
performed work at the Girdwood Residence.
42. STEVENS also thanked VECO employees and contractors who performed tasks
at the Girdwood Residence. STEVENS did this through correspondence and conversations with
ALLEN, with PERSON A, and with multiple VECO employees and contractors.
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43. As an example, on or about November 11, 2004, STEVENS sent a handwritten
letter addressed to a VECO electrician at VECO's corporate address in which STEVENS stated,
"Thanks for fixing the heat tape. It seems to be working ok now."
44. In or about the summer of 2001, ALLEN gave STEVENS other items of value,
including new and used furniture, a new stationary tool storage cabinet with new tools, and a new
professional Viking gas grill. Each of these things of value was worth greater than $260.00.
45. For calendar years 1999 through 2006, STEVENS filed and caused to be filed
with the Secretary of the Senate a yearly Financial Disclosure Form. For calendar years 1999
through 2006, each year's Financial Disclosure Form required STEVENS to report the things of
value he received that have been described at Paragraphs 18 through 44 herein.
46. STEVENS knew the requirements of the Financial Disclosure Forms, and
knowingly and intentionally sought to conceal and cover up his receipt of things of value by
filing Financial Disclosure Forms that contained false statements and omissions concerning
STEVENS' receipt of these things of value.
All in violation of Title 18, United States Code, Section 1001(a)(1) and (c)(1) and (2).
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COUNT TWO
FALSE STATEMENTS
(18 U.S.C. � 1001(a)(2))
47. Paragraphs 1-14, 19-25, and 37-44 of this Indictment are realleged as if set forth
fully herein.
STEVENS' 2001 Senate Financial Disclosure Form
48. On or about May 15, 2002, STEVENS filed and caused to be filed a signed
document titled "United States Senate Public Financial Disclosure Report For Annual and
Termination Reports" (hereinafter "2001 Financial Disclosure Form"). The 2001 Financial
Disclosure Form was a document required by rule to be submitted to and filed with the Secretary
of the Senate, an office within the legislative branch of the United States Government. The 2001
Financial Disclosure Form was signed by STEVENS and hand-dated "May 15, 2002."
49. The 2001 Financial Disclosure Form required STEVENS to identify and report his
receipt of gifts, with an aggregate value of greater than $260.00 from any single source, received
by STEVENS, his spouse, and his dependent children during calendar year 2001. The 2001
Financial Disclosure Form also required STEVENS to identify and report any liabilities greater
than $10,000 owed by STEVENS, his spouse, and his dependent children at any time during
calendar year 2001.
50. The first page of the 2001 Financial Disclosure Form contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child receive any reportable
gift in the reporting period (i.e., aggregating more than $260 and
not otherwise exempt)? If yes, Complete and Attach PART V.
On the 2001 Financial Disclosure Form, STEVENS checked the "NO" box, and did not attach a
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completed Part V form.
51. The first page of the 2001 Financial Disclosure Form also contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child have any reportable
liability (more than $10,000) in the reporting period? If yes,
Complete and Attach PART VII.
On the 2001 Financial Disclosure Form, STEVENS checked the "NO" box, and did not attach a
completed Part VII form.
52. On or about May 15, 2002, in the District of Columbia and elsewhere, in a matter
within the jurisdiction of the legislative branch of the Government of the United States and
subject to the legislative function exception, that is, the United States Senate and the Secretary of
the United States Senate, defendant STEVENS knowingly and willfully made and caused to be
made material false, fictitious, and fraudulent statements and representations, that is, STEVENS
falsely reported and caused to be reported on his 2001 Financial Disclosure Form and
attachments thereto, which he then certified, signed, filed and caused to be filed with the
Secretary of the Senate, that during calendar year 2001 he had received no gifts from a single
source with an aggregate value of more than $260.00, and that he had no liabilities in an amount
greater than $10,000, when in truth and in fact STEVENS knew that his transactions with,
including his receipt of things of value from, ALLEN, VECO, PERSON A and PERSON B were
required to be reported either as gifts or as liabilities on his 2001 Financial Disclosure Form.
All in violation of Title 18, United States Code, Section 1001(a)(2) and (c)(1) and (2).
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COUNT THREE
FALSE STATEMENTS
(18 U.S.C. � 1001(a)(2))
53. Paragraphs 1-14, 19-27, and 37-44 of this Indictment are realleged as if fully set
forth herein.
STEVENS' 2002 Senate Financial Disclosure Form
54. On or about May 13, 2003, STEVENS filed and caused to be filed a signed
document titled "United States Senate Public Financial Disclosure Report For Annual and
Termination Reports" (hereinafter "2002 Financial Disclosure Form"). The 2002 Financial
Disclosure Form was a document required by rule to be submitted to and filed with the Secretary
of the Senate, an office within the legislative branch of the United States Government. The 2002
Financial Disclosure Form was signed by STEVENS and hand-dated "May 13, 2003."
55. The 2002 Financial Disclosure Form required STEVENS to identify and report his
receipt of gifts, with an aggregate value of greater than $260.00 from any single source, received
by STEVENS, his spouse, and his dependent children during calendar year 2002. The 2002
Financial Disclosure Form also required STEVENS to identify and report any liabilities greater
than $10,000 owed by STEVENS, his spouse, and his dependent children at any time during
calendar year 2002.
56. The first page of the 2002 Financial Disclosure Form contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child receive any reportable
gift in the reporting period (i.e., aggregating more than $260 and
not otherwise exempt)? If yes, Complete and Attach PART V.
On the 2002 Financial Disclosure Form, STEVENS checked the "NO" box, and did not attach a
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completed Part V form.
57. The first page of the 2002 Financial Disclosure Form also contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child have any reportable
liability (more than $10,000) in the reporting period? If yes,
Complete and Attach PART VII.
On the 2002 Financial Disclosure Form, STEVENS checked the "NO" box, and did not attach a
completed Part VII form.
58. On or about May 13, 2003, in the District of Columbia and elsewhere, in a matter
within the jurisdiction of the legislative branch of the Government of the United States and
subject to the legislative function exception, that is, the United States Senate and the Secretary of
the United States Senate, defendant STEVENS knowingly and willfully made and caused to be
made material false, fictitious, and fraudulent statements and representations, that is, STEVENS
falsely reported and caused to be reported on his 2002 Financial Disclosure Form and
attachments thereto, which he then certified, signed, filed and caused to be filed with the
Secretary of the Senate, that during calendar year 2002 he had received no gifts from a single
source with an aggregate value of more than $260.00, and that he had no liabilities in an amount
greater than $10,000, when in truth and in fact STEVENS knew that his transactions with,
including his receipt of things of value from, ALLEN, VECO, PERSON B, and others were
required to be reported either as gifts or as liabilities on his 2002 Financial Disclosure Form.
All in violation of Title 18, United States Code, Section 1001(a)(2) and (c)(1) and (2).
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COUNT FOUR
FALSE STATEMENTS
(18 U.S.C. � 1001(a)(2))
59. Paragraphs 1-14, 19-27, and 37-44 of this Indictment are realleged as if fully set
forth herein.
STEVENS' 2003 Senate Financial Disclosure Form
60. On or about May 17, 2004, STEVENS filed and caused to be filed a signed
document titled "United States Senate Public Financial Disclosure Report For Annual and
Termination Reports" (hereinafter "2003 Financial Disclosure Form"). The 2003 Financial
Disclosure Form was a document required by rule to be submitted to and filed with the Secretary
of the Senate, an office within the legislative branch of the United States Government. The 2003
Financial Disclosure Form was signed by STEVENS and hand-dated "May 17, 2004."
61. The 2003 Financial Disclosure Form required STEVENS to identify and report his
receipt of gifts, with an aggregate value of greater than $285.00 from any single source, received
by STEVENS, his spouse, and his dependent children during calendar year 2003. The 2003
Financial Disclosure Form also required STEVENS to identify and report any liabilities greater
than $10,000 owed by STEVENS, his spouse, and his dependent children at any time during
calendar year 2003.
62. The first page of the 2003 Financial Disclosure Form contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child receive any reportable
gift in the reporting period (i.e., aggregating more than $285 and
not otherwise exempt)? If yes, Complete and Attach PART V.
On the 2003 Financial Disclosure Form, STEVENS checked the "YES" box, and attached a
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completed Part V form in which STEVENS listed receiving a gift in 2003 from the "[Fishing
Association] 501(c)(3)." The gift was described as being "given as honorary award in
recognition of public service," and was listed as having a value of $250.00.
63. The first page of the 2003 Financial Disclosure Form also contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child have any reportable
liability (more than $10,000) in the reporting period? If yes,
Complete and Attach PART VII.
On the 2003 Financial Disclosure Form, STEVENS checked the "NO" box, and did not attach a
completed Part VII form.
64. On or about May 17, 2004, in the District of Columbia and elsewhere, in a matter
within the jurisdiction of the legislative branch of the Government of the United States and
subject to the legislative function exception, that is, the United States Senate and the Secretary of
the United States Senate, defendant STEVENS knowingly and willfully made and caused to be
made material false, fictitious, and fraudulent statements and representations, that is, STEVENS
falsely reported and caused to be reported on his 2003 Financial Disclosure Form and
attachments thereto, which he then certified, signed, filed and caused to be filed with the
Secretary of the Senate, that (1) during calendar year 2003 he received a gift, valued at $250.00,
from the Fishing Association in recognition of STEVENS' public service, when STEVENS in
fact and in truth knew that the gift was actually given to him by PERSON B, and had a value of
greater than $285.00, and (2) that during calendar year 2003 he had received no other gifts from a
single source with an aggregate value of more than $285.00, and that he had no liabilities in an
amount greater than $10,000, when in truth and in fact STEVENS knew that his transactions
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Case 1:08-cr-00231-EGS Document 1 Filed 07/29/2008 Page 20 of 28
with, including his receipt of things of value from, ALLEN and VECO were required to be
reported either as gifts or as liabilities on his 2003 Financial Disclosure Form.
All in violation of Title 18, United States Code, Section 1001(a)(2) and (c)(1) and (2).
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Case 1:08-cr-00231-EGS Document 1 Filed 07/29/2008 Page 21 of 28
COUNT FIVE
FALSE STATEMENTS
(18 U.S.C. � 1001(a)(2))
65. Paragraphs 1-14, 19-31, and 37-44 of this Indictment are realleged as if fully set
forth herein.
STEVENS' 2004 Senate Financial Disclosure Form
66. On or about May 16, 2005, STEVENS filed and caused to be filed a signed
document titled "United States Senate Public Financial Disclosure Report For Annual and
Termination Reports" (hereinafter "2004 Financial Disclosure Form"). The 2004 Financial
Disclosure Form was a document required by rule to be submitted to and filed with the Secretary
of the Senate, an office within the legislative branch of the United States Government. The 2004
Financial Disclosure Form was signed by STEVENS and hand-dated "May 16, 2005."
67. The 2004 Financial Disclosure Form required STEVENS to identify and report his
receipt of gifts, with an aggregate value of greater than $305.00 from any single source, received
by STEVENS, his spouse, and his dependent children during calendar year 2004. The 2004
Financial Disclosure Form also required STEVENS to identify and report any liabilities greater
than $10,000 owed by STEVENS, his spouse, and his dependent children at any time during
calendar year 2004.
68. The first page of the 2004 Financial Disclosure Form contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child receive any reportable
gift in the reporting period (i.e., aggregating more than $305 and
not otherwise exempt)? If yes, Complete and Attach PART V.
On the 2004 Financial Disclosure Form, STEVENS checked the "YES" box, and attached a
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Case 1:08-cr-00231-EGS Document 1 Filed 07/29/2008 Page 22 of 28
completed Part V form in which STEVENS disclosed the receipt of four gifts, totaling $1,428,
from dignitaries of three foreign governments. STEVENS did not list receiving any gifts from
ALLEN or VECO on the Part V form attached to his 2004 Financial Disclosure Form.
69. The first page of the 2004 Financial Disclosure Form also contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child have any reportable
liability (more than $10,000) in the reporting period? If yes,
Complete and Attach PART VII.
On the 2004 Financial Disclosure Form, STEVENS checked the "YES" box, and attached a
completed Part VII form in which STEVENS disclosed a liability to the Internal Revenue Service
of an amount within a range from $100,001 to $250,000. STEVENS did not list having any
liabilities or owing any debts to ALLEN or VECO on the Part VII form attached to his 2004
Financial Disclosure Form.
70. On or about May 16, 2005, in the District of Columbia and elsewhere, in a matter
within the jurisdiction of the legislative branch of the Government of the United States and
subject to the legislative function exception, that is, the United States Senate and the Secretary of
the United States Senate, defendant STEVENS knowingly and willfully made and caused to be
made material false, fictitious, and fraudulent statements and representations, that is, STEVENS
falsely reported and caused to be reported on his 2004 Financial Disclosure Form and
attachments thereto, which he then certified, signed, filed and caused to be filed with the
Secretary of the Senate, that during calendar year 2004 he had received no gifts from either
ALLEN or VECO with an aggregate value of more than $305.00, and that he had no liabilities to
ALLEN or VECO in an amount greater than $10,000, when in truth and in fact STEVENS knew
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Case 1:08-cr-00231-EGS Document 1 Filed 07/29/2008 Page 23 of 28
that his transactions with, including his receipt of things of value from, ALLEN and VECO were
required to be reported either as gifts or as liabilities on his 2004 Financial Disclosure Form.
All in violation of Title 18, United States Code, Section 1001(a)(2) and (c)(1) and (2).
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Case 1:08-cr-00231-EGS Document 1 Filed 07/29/2008 Page 24 of 28
COUNT SIX
FALSE STATEMENTS
(18 U.S.C. � 1001(a)(2))
STEVENS' 2005 Senate Financial Disclosure Form
71. Paragraphs 1-14, 19-3 1, and 37-44 of this Indictment are realleged as if fully set
forth herein.
72. On or about May 15, 2006, STEVENS filed and caused to be filed a signed
document titled "United States Senate Public Financial Disclosure Report For Annual and
Termination Reports" (hereinafter "2005 Financial Disclosure Form"). The 2005 Financial
Disclosure Form was a document required by rule to be submitted to and filed with the Secretary
of the Senate, an office within the legislative branch of the United States Government. The 2005
Financial Disclosure Form was signed by STEVENS and hand-dated "May 15, 2006."
73. The 2005 Financial Disclosure Form required STEVENS to identify and report his
receipt of gifts, with an aggregate value of greater than $305.00 from any single source, received
by STEVENS, his spouse, and his dependent children during calendar year 2005. The 2005
Financial Disclosure Form also required STEVENS to identify and report any liabilities greater
than $10,000 owed by STEVENS, his spouse, and his dependent children at any time during
calendar year 2005.
74. The first page of the 2005 Financial Disclosure Form contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child receive any reportable
gift in the reporting period (i.e., aggregating more than $305 and
not otherwise exempt)? If yes, Complete and Attach PART V.
On the 2005 Financial Disclosure Form, STEVENS checked the "NO" box, and did not attach a
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Case 1:08-cr-00231-EGS Document 1 Filed 07/29/2008 Page 25 of 28
completed Part V form.
75. The first page of the 2005 Financial Disclosure Form also contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child have any reportable
liability (more than $10,000) in the reporting period? If yes,
Complete and Attach PART VII.
On the 2005 Financial Disclosure Form, STEVENS checked the "NO" box, and did not attach a
completed Part VII form.
76. On or about May 15, 2006, in the District of Columbia and elsewhere, in a matter
within the jurisdiction of the legislative branch of the Government of the United States and
subject to the legislative function exception, that is, the United States Senate and the Secretary of
the United States Senate, defendant STEVENS knowingly and willfully made and caused to be
made material false, fictitious, and fraudulent statements and representations, that is, STEVENS
falsely reported and caused to be reported on his 2005 Financial Disclosure Form and
attachments thereto, which he then certified, signed, filed and caused to be filed with the
Secretary of the Senate, that during calendar year 2005 he had received no gifts from a single
source with an aggregate value of more than $305.00, and that he had no liabilities in an amount
greater than $10,000, when in truth and in fact STEVENS knew that his transactions with,
including his receipt of things of value from, ALLEN and VECO were required to be reported
either as gifts or as liabilities on his 2005 Financial Disclosure Form.
All in violation of Title 18, United States Code, Section 1001(a)(2) and (c)(1) and (2).
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Case 1:08-cr-00231-EGS Document 1 Filed 07/29/2008 Page 26 of 28
COUNT SEVEN
FALSE STATEMENTS
(18 U.S.C. � 1001(a)(2))
STEVENS' 2006 Senate Financial Disclosure Form
77. Paragraphs 1-14 and 19-44 of this Indictment are realleged as if fully set forth
herein.
78. On or about July 17, 2007, STEVENS filed and caused to be filed a signed
document titled "United States Senate Public Financial Disclosure Report For Annual and
Termination Reports" (hereinafter "2006 Financial Disclosure Form"). The 2006 Financial
Disclosure Form was a document required by rule to be submitted to and filed with the Secretary
of the Senate, an office within the legislative branch of the United States Government. The 2006
Financial Disclosure Form was signed by STEVENS and hand-dated "July 17, 2007."
79. The 2006 Financial Disclosure Form required STEVENS to identify and report his
receipt of gifts, with an aggregate value of greater than $305.00 from any single source, received
by STEVENS, his spouse, and his dependent children during calendar year 2006. The 2006
Financial Disclosure Form also required STEVENS to identify and report any liabilities greater
than $10,000 owed by STEVENS, his spouse, and his dependent children at any time during
calendar year 2006.
80. The first page of the 2006 Financial Disclosure Form contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child receive any reportable
gift in the reporting period (i.e., aggregating more than $305 and
not otherwise exempt)? If yes, Complete and Attach PART V.
On the 2006 Financial Disclosure Form, STEVENS checked the "YES" box, and attached a
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Case 1:08-cr-00231-EGS Document 1 Filed 07/29/2008 Page 27 of 28
completed Part V form in which STEVENS disclosed the receipt of a single gift, valued at
$1,400, from a charitable organization. STEVENS did not list receiving any gifts from ALLEN
or VECO on the Part V form attached to his 2006 Financial Disclosure Form.
81. The first page of the 2006 Financial Disclosure Form also contained the following
question, followed by boxes for "YES" and "NO":
Did you, your spouse, or dependent child have any reportable
liability (more than $10,000) in the reporting period? If yes,
Complete and Attach PART VII.
On the 2006 Financial Disclosure Form, STEVENS checked the "NO" box, and did not attach a
completed Part VII form.
82. On or about July 17, 2007, in the District of Columbia and elsewhere, in a matter
within the jurisdiction of the legislative branch of the Government of the United States and
subject to the legislative function exception, that is, the United States Senate and the Secretary of
the United States Senate, defendant STEVENS knowingly and willfully made and caused to be
made material false, fictitious, and fraudulent statements and representations, that is, STEVENS
falsely reported and caused to be reported on his 2006 Financial Disclosure Form and
attachments thereto, which he then certified, signed, filed and caused to be filed with the
Secretary of the Senate, that during calendar year 2006 he had received no gifts from ALLEN or
VECO with an aggregate value of more than $305.00, and that he had no liabilities in an amount
greater than $10,000, when in truth and in fact STEVENS knew that his transactions with,
including his receipt of things of value from, ALLEN and VECO were required to be reported
either as gifts or as liabilities on his 2006 Financial Disclosure Form.
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Case 1:08-cr-00231-EGS Document 1 Filed 07/29/2008 Page 28 of 28
All in violation of Title 18, United States Code, Section 1001(a)(2) and (c)(1) and (2).
A TRUE BILL.
Dated:
Foreperson
WILLIAM M. WELCH II
Chief, Public Integrity Section
By:
BRENDA K. MORRIS
Principal Deputy Chief
NICHOLAS A. MARSH
EDWARD P. SULLIVAN
Trial Attorneys
Public Integrity Section
Criminal Division
United States Department of Justice
1400 New York Avenue N.W.
Washington, D.C. 20005
JOSEPH W. BOTTINI
JAMES A. GOEKE
Assistant United States Attorneys
for the District of Alaska
Federal Building & U.S. Courthouse
222 West Seventh Avenue
Anchorage, Alaska 99513-7567
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