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FILED
2013 DEC -6 PH 4: 57
tLS. CCUPT
WHRAL DIST. CF CAL! F.'
LUS A:1GELES
GY=--------
UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
October 2013 Grand Jury
UNITED STATES OF AMERICA,
No. CR uC
Plaintiff,
v.
CEDRIC EARL HUGHES,
Defendant.
I N D I C T M E N T
[29 U.S.C. 501(c):
Embezzlement and Theft of Labor
Union Assets; 18 U.S.C. 1343:
Wire Fraud.]
The Grand Jury charges:
INTRODUCTORY ALLEGATIONS
1.
At all times material to this Indictment, United Union
20 Professionals ("UUP") was a labor organization engaged in an
21 industry affecting commerce within the meaning of the Labor
22 Management Reporting and Disclosure Act of 1959 and as defined in
23 Title 29, United States Code, Sections 402(a)-(c), (i), and (j).
24 2. From at least in or about March 2009 until on or about
25 June 22, 2010, defendant CEDRIC EARL HUGHES ("HUGHES") was an
26 officer and the Treasurer of UUP.
27 3.
From at least in or about July 2009 until in or about
28 November 2010, defendant HUGHES was a signatory on Chase Bank
Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 1 of 6 Page ID #:1
1 checking account number XXX-XXXX877-9 (the "UUP Chase Account")
2 and had possession of a debit card which could be used to
3 withdraw funds from the UUP Chase Account. During the time that
4 defendant HUGHES was the Treasurer of UUP, defendant HUGHES's
5 responsibilities included, among others, to make withdrawals from
6 the UUP Chase Account if those withdrawals were authorized by the
7 UUP Board.
8 4.
These introductory allegations are hereby incorporated
9 by reference into each count of this Indictment as though fully
10 set forth therein.
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Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 2 of 6 Page ID #:2
1 COUNT ONE
2 [29 u.s.c. 501(c)J
3 On or about May 26, 2010, in Los Angeles County, within the
4 Central District of California, and elsewhere, defendant CEDRIC
5 EARL HUGHES, while an officer of United Union Professionals
6 ("UUP"), knowingly and with intent to defraud, embezzled, stole,
7 and unlawfully and willfully abstracted and converted to his own
8 use and the use of others, the moneys, funds, securities,
9 property and other assets of UUP by depositing into his own
10 personal bank account without authorization from the UUP Board
11 Check Number 1570, dated May 26, 2010, from the UUP Chase
12 Account, in the approximate amount of $500.00.
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Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 3 of 6 Page ID #:3
1 COUNT TWO THROUGH SIX
2 [18 u.s.c. 1343]
3 Beginning on or about May 26, 2010, and continuing through
4 on or about November 8, 2010, in Los Angeles County, within the
5 Central District of California, and elsewhere, defendant CEDRIC
6 EARL HUGHES ("HUGHES"), knowingly and with the intent to defraud,
7 devised, participated in, and executed a scheme to defraud United
8 Union Professionals ("UUP") as to material matters, and to obtain
9 money and property from UUP by means of material false and
10 fraudulent pretenses, representations, and promises, and the
11 concealment of material facts.
12 A.
13
SCHEME TO DEFRAUD
The fraudulent scheme operated, in substance, in the
14 following manner:
15 1. Defendant HUGHES made withdrawals from the UUP Chase
16 Account that were not authorized by the UUP Board, and which were
17 for his own personal use, by writing checks to himself which were
18 drawn on the UUP Chase Account, by making debit card purchases
19 using the debit card linked to the UUP Chase Account, and by
20 making cash withdrawals from the UUP Chase Account.
21 2. In order to conceal the withdrawals from officers at
22 UUP and to continue making withdrawals undetected, defendant
23 HUGHES knowingly and falsely told UUP officers that the checkbook
24 and other financial records for the UUP Chase Account had gone
25 missing when defendant HUGHES's truck was stolen.
26 3. In order to continue making withdrawals undetected,
27 defendant HUGHES failed to return the debit card for the UUP
28 Chase Account after he was asked to do so by UUP officers.
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Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 4 of 6 Page ID #:4
1 4 . In order to conceal the purpose of the checks that he
2 wrote to himself from the UUP Chase Account, defendant HUGHES
3 knowingly made false and misleading statements on the memo lines
4 of the checks.
5 5. As a result of the above-described fraudulent scheme,
6 defendant HUGHES caused approximately $15,193.75 in losses from
7 the UUP Chase Account.
8 B. USE OF THE WIRES
9 On or about the dates set forth below, in Los Angeles
10 County, in the Central District of California, and elsewhere,
11 defendant HUGHES, for the purpose of executing and attempting to
12 execute the above-described scheme to defraud, transmitted and
13 caused the transmission of the following items by means of wire
14 and radio communication in interstate and foreign commerce:
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Count
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TWO
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FOUR
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Date
05/26/2010
07/02/2010
07/12/2010
08/13/2010
Wire Transmission
Electronic request sent via interstate
wire, requesting the transfer of
$500.00 for payment of Check #1570 from
the UUP Chase Account.
Electronic request sent via interstate
wire, requesting the transfer of
$1,013.49 for payment of Check #1577
from the UUP Chase Account.
Electronic request sent via interstate
wire, requesting the transfer of
$1,500.00 for payment of Check #1580
from the UUP Chase Account.
Electronic request sent via interstate
wire, requesting the transfer of
$1,500.00 for payment of Check #1596
from the UUP Chase Account.
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Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 5 of 6 Page ID #:5
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Count Date Wire Transmission
SIX 10/18/2010 Internet debit card purchase of airline
tickets from Orbitz.com, in the amount
of $573.19, using the UUP Chase
Account, made via interstate wire
communication.
ANDRE BIROTTE JR.
United States Attorney
()v Cz.u
ROBERT E. DUGDALE
Assistant United States Attorney
Chief, Criminal Division
LAWRENCE S. MIDDLETON
Assistant United States Attorney
A TRUE BILL
/6/
Foreperson
Chief, Public Corruption & Civil Rights
Section
MARGARET L. CARTER
Assistant United States Attorney
Public Corruption and Civil Rights Section
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Case 2:13-cr-00871-UA Document 1 Filed 12/06/13 Page 6 of 6 Page ID #:6