Michael Lynn Vaughn Indictment

Case 8:17-cr-00125-PX Document 1 Filed 03/06/17 Page 1 of 20
\j.P T/,WI~lSKJAGR: USAO 2017ROOl47
IN THE UNITED STATES DISTRICT COURT

,~,
FOR THE DISTRICT OF MARYLAND
UNITED STATES OF AMERICA *

*
v. * CRIMINAL NO. PX. l L c..r (~S-
*
MICHAEL LYNN VAUGHN, * (Conspiracy, 18 U.S.c. ~ 371;
* Bribery Involving Agent of a
Defendant * Program Receiving Federal Funds,
* 18 U.S.c. ~ 666(a)(I)(B); Wire
* Fraud, 18 U.S.c. ~ 1343; Forfeiture,
* 18 U.S.c. ~ 981(a)(1)(C), 21 U.S.c.
* ~ 853, and 28 U.S.c. ~ 246 I(e
*
*******
INDICTMENT
COUNT ONE
(Conspiracy)
The Grand Jury for the District of Maryland charges that:
Introduction
At all times relevant to this Indictment;
Marvland State Governmellf
I. The General Assembly was the State of Maryland's legislative body. The
bicameral legislature was composed of the Senate, with 47 Senators, and the House of Delegates,
with 141 Delegates.
2. The State of Maryland was a state govenunent that received, in each relevant one-
ycar period, benefits in excess of$ I0,000 under a Federal program involving a grant, contract,
subsidy, loan guarantee, insurance, and other fonn of Federal assistance.

3. Maryland state law prohibited a person from giving a public employee, and
prohibited a public employee from demanding or receiving, a bribe, fee, reward or testimonial in
exchange for influencing the performance of the official duties of the public employee, or
neglecting or failing to perfornl the official duties of the public employee, as provided by
Maryland Code, Criminal Law, S 9-20 I.

4. Maryland state law required certain State officials, employees, and candidates for
office to file annual financial disclosure statements.
5. The Maryland State Ethics Commission, as directed in Maryland Code, General
Provisions, S 5-205, administered the provisions of the Maryland Public Ethics Law.
The Defendant
6. The defendant, MICHAEL LYNN VAUGHN ("VAUGHN"), was a Maryland
State Delegate !Tom January 2003 until January 2017, representing District 24, which covered
portions of Prince George's County, Maryland. VAUGHN was the Deputy Majority Whip and
was a member of the Economic Matters Committee.
Other Organizations and Persons
7. David Dae Sok Son ("Son") was appointed in 2005 by the Governor of
Maryland to serve as a commissioner on the Prince George's County Board of License
Commissioners ("Liquor Board"), a position he held continuously until late 2014. Among other
official action, the Board enforced the state's Alcohol Beverage Laws in Prince George's
County. During the 2015 Maryland legislative session, Son served as a liaison for the Prince
George's County Senate Delegation. Later in 2015, Son returned to the Liquor Board, this time
as its Chief Liquor Inspector.
2
8. Young Jung Paig ("Paig"), a Maryland resident, was the owner of Central
Avenue Restaurant & Liquor Store and the resident agent of Weeping Willow, Inc., in Prince
George's County, Maryland.
9. Shin Ja Lee ("Lee"), a Maryland resident, was the owner of Palmer Liquor Store
and the resident agent of Multi-Bil, Inc., in Prince George's County, Maryland.
10. Confidential Human Source 7 ("CHS-7") had a close business and personal
relationship with Son.
Marvland State Legislation
11. Under Maryland law, alcohol licenses were divided into different classes. Class
A licenses authorized their holders to sell, for consumption off the premises, beer, wine, and
liquor six days per week. Class B licenses authorized their holders to sell beer and wine seven
days per week and liquor every day except Sunday; certain Class B licenses were for
consumption on the premises, while other Class B licenses had an off-sale privilege.
12. House Bill 931 (Prince George's County Bill 318-15) ("PG 318-15" or "Sunday
Sales Bill") established up to 100 Sunday liquor sales permits in Prince George's County for
holders of Class A licenses and Class B licenses with an off-sale privilege. On March 20, 2015,
PG 318-15 passed the House Economic Matters Committee, with VAUGHN voting in favor.
PG 318-15 passed the House on or about March 23, 2015 (with VAUGHN again voting in
favor), was returned passed by the Senate on April 9, 2015, and was approved by the Governor
on April 14, 2015.
13. House Bill 1311 (Prince George's County Bill 305-16) ("PG 305-16" or
"Additional Sunday Permits Bill") raised the limit of Sunday liquor sales permits in Prince
George's County from I00 to 105, and authorized the additional five permits "only to holders of
3
a Class B beer, wine, and liquor license with an off-sale privilege that acquired the license on or
after January 1,2016." As written, the bill was expressly designed to encompass only a limited
number of potential recipients. On March 15,2016, PG 305-16 passed the House Economic
Matters Committee, with VAUGHN voting in favor. PG 305-16 unanimously passed the full
House on March 17,2016 (with VAUGHN again voting in favor), was returned passed by the
Senate on April I I, 2016, and was approved by the Governor on April 26, 2016.
Details of the Pav-to-Play Bribery Conspiracy
14. VAUGHN conspired with Son and others in order to enrich himself personally, in
exchange for VAUGHN performing and agreeing to perform favorable official action.
VAUGHN also took cash bribe payments from Paig, Lee, and others, in exchange for
influencing and voting for the Sunday Sales Bill and the Additional Sunday Permits Bill.
The Earlv 2015 Bribe Pavmen/
15. In or about April 2015, VAUGHN accepted $2,000 in cash from Lee, and $2,000
from another individual, in a meeting organized and attended by Son. The cash was in exchange
for VAUGHN's assistance in obtaining passage of PG 318-15, after which Lee expected to
obtain a Sunday Sales permit. VAUGHN then deposited the cash into bank accounts VAUGHN
controlled.
The November 2015 Bribe Pavmen/
16. On October 19, 2015, during a consensually recorded meeting, Son and CHS-7
discussed the Sunday Sales Bill permits. Son stated that he had talked to VAUGHN about a
moratorium on any morc Sunday Sales permits, which would bcnefit Paig and Lee, who already
had obtained Sunday Salcs permits after the passage of PG 318-15. Son told CHS-7 that "Mike
4
[VAUGHN] is on board." Son explained that Paig was willing to pay $50,000 for a
moratorium.
17. On October 21, 2015, during a consensually recorded meeting, Son and CHS.7
discussed VAUGHN and VAUGHN's request for a bribe payment in return for official
assistance with the moratorium on Sunday Sales. Son detailed how he would serve as the
middleman to facilitate a bribe payment from Paig and Lee to VAUGHN in return for
VAUGHN's official assistance. During the meeting, CHS-7 asked, "How we going to do it with
Mike? Mike Vaughn." Son said, "So, Mike Vaughn goes, 'You know, I need your help. You
know, I need, I need a couple thousand. I need, two ... two thousand. '" Son explained that
VAUGHN had agreed to sponsor legislation beneficial to Paig and Lee and had told Son that he
was going to "put it in now. Would that, would that, you know, kinda get your guys excited
about it? We'll get it done." Son then agreed to set up a meeting with Pail: and Lee to facilitate
the bribe payment to VAUGHN.
18. Later in the same meeting, Son told CHS- 7 that Paig and Lee were willing to pay
$5,000 or $10,000 in cash in order to get the legislation approved, stating, "[Paig and Lee] want
it bad" and "for them, five or ten is nothing for them." Son then stated, "My thought was, why
do we need to get our hands dirty on that. Let 'em be direct .... That's what we did last time."
Later, Son advised, "So I will go out of my way to meet with [Paig and Lee] and be like, look,
consider this as a deposit. Urn. You all could just sort that shit out. I think the matching number
is this. You all meet and you all could just take care of that. [VAUGHN]'l1 take care of the rest.
I mean, getting a bill sponsored, is like ... is hard. They don't want anything blowing back and
shit like that. [VAUGHN]'s will[ing] to do it." At the end of the conversation, CHS-7
5
confirmed with Son that Paig and Lee were to provide a bribe payment to VAUGHN in
exchange for his official assistance.
19. On November 9, 2015, during a consensually recorded meeting, Son and CHS-7
discussed VAUGHN, Lee, and Paig. Son told CHS-7 that [Lee and PaigJ were "down. 100%."
SOli told CHS-7 that VAUGHN would be meeting with Lee and Paig to "ink the deal" and that
they are "putting a down payment on it."
20. On November 10,2015, VAUGHN met with Son, Paig, and Lee at a restaurant
in Bowie, Maryland. After meeting in the restaurant, VAUGHN and Paig went to the parking
lot and entered VAUGHN's car. While in the car, Paig provided VAUGHN with two separate
payments of$2,000 in cash bribes ($2,000 each from Paig and Lee) in return for VAUGHN's
official assistance with legislation regarding Sunday Sales permits that would benefit Paig and
Lee's liquor stores. Paig then got out of VAUGHN's vehicle and rejoined Son and Lee, who
were still standing at the front entrance of the restaurant.
21. Upon leaving the parking lot in his vehicle, VAUGHN drove directly to the
Capital One Bank, which was in the same shopping area as the restaurant. VAUGHN first
pulled up to the drive-thru teller/ATM and made a $2,000 ATM cash deposit. Shortly
afterwards, VAUGHN parked in front of the Capital One bank and entered it. Upon
approaching the teller inside the bank, VAUGHN pulled a stack of cash out of his right pocket
and handed it to the teller. VAUGHN then pulled a stack of cash out of his left pocket and,
again, handed it to the teller. The total deposit made by VAUGHN inside the bank also was
$2,000.
6
The Februarv 2016 and April 2016 Bribe Pavmenls
22. PG 305-16 did not start off as a bill designed to create additional Sunday Sales
pennits. At the inception of the 2016 legislative session, VAUGHN opposed PG 305-16
because it would allow certain business owners to obtain a development district alcohol license,
which in turn would create increased competition to existing license holders such as Paig and
Lee, from whom VAUCHN had accepted bribe payments to promote and protect their
businesses from competition.
23. On January 27,2016, VAUGHN placed an outgoing phone call to Son. Referring
to PG 305-16, VAUGHN was upset that certain business owners were attempting to obtain
particular alcohol "through legislation [that] circumvents the whole process." Son agreed and
stated that these businesses did not want "to pay the price. They want to go down to Annapolis
and try to change something."
24. On February 3, 2016, CHS-7 met with Son to discuss liquor legislation and to
discuss the status of certain bribe payments from Paig and Lee. Son suggested that Paig and
Lee would find it difficult to successfully promote protective legislation for which they made the
November 2015 bribe payment while concurrently defending against the new legislation that
would add licenses to circumvent the system.
25. On February 3, 20 16, VAUGHN contacted other Maryland legislators in an effort
to block the version of the bill that was unfavorable to Paig and Lee, as VAUGHN had been
instructed by Son. In one conversation, VAUGHN reminded another elected official that the
legislation had to pass through VAUGHN's Economic Matters Committee ("ECM") and that
VAUGHN would use his position on the committee to amend or kill the proposed legislation,
explaining, "At the end of the day, ECM has final say so. So, I'm, I'm gonna be, I'm gonna be
7
checking. I'm gonna be checking and double checking. Making sure none of this bullshit slip
through."
26. On February II, 2016, CHS-7, Son, and VAUGHN met in Annapolis, Maryland,
and discussed a plan to benefit Paig and Lee by amending PO 305-16. The new bill language
would, as Son said, "close the door" to certain license classes receiving the enhanced ability to
sell liquor, while only slightly expanding the number of Sunday Sales permits. VAUGHN
understood that once the liquor legislation passed, it would limit future competition for Paig and
Lee, and that I'aig and Lee would provide money to VAUGHN in exchange for VAUGHN's
official assistance.
27. On February 12, 2016, CHS-7 and Son met to discuss VAUGHN. Son stated that
VAUGHN was "happy cause now he [VAUGHN] has a say. Better give him like five O's
man."
28. Later in February 2016, VAUGHN was determined to hold the Additional
Sunday Permits Bill in his committee, so that the hold would create pressure on other elected
officials to support another bill. On Febnlary 19,2016, VAUGHN received an incoming call
from Son. VAUGHN stated that PO 305-16 "ain't out the woods yet. And it got out of Law
Enforcement [Committee] but, it's coming to ECM [Economic Matters Committee] on Monday.
'Cause we have liquor bills on Monday." At the end of the call, VAUGHN advised, "[PO 305-
16] ain't, ain't going nowhere yet. It's still, it's still within reach." By this time, though, Son,
Paig, and Lee supported thc amcnded version of the Additional Sunday Permits Bill, becausc it
would effectively limit future competition for Paig and Lee.
29. On February 24, 2016, CHS-7 met with Son in College Park, Maryland, to
discuss liquor legislation. During the meeting, Son and CHS-7 discussed how CHS-7 need cd to
8
provide VAUGHN with a bribe payment to ensure the passage of PG 305-16. Son confinned
that CHS-7 should provide VAUGHN with $2,000 for VAUGHN's assistance with PG 305-16
and give Son $1,000 for Son's help in facilitating the legislation, explaining, "Mike's gOnlJa be
loving your ass."
30. On February 26,2016, CHS-7 met with Son at a restaurant in Bowie, Maryland,
just prior to a meeting arranged in order for CHS-7 to provide VAUGHN with a bribe payment.
During the meeting, Son asked if CHS- 7 had put "that G to a side for me. Do you wanna do it
under the table?" CHS-7 said he left the bribe money in the car. CHS- 7 asked if he should go to
his car. Son replied, "You might ... do his ... when he's here too," and, "This is his district and
shit, so." CHS asked, "Under table?" Son replied, "Yeah, yeah. Should be alright." CHS-7 left
the restaurant, returned, and then handed $1,000 in cash to Son, who concealed the money in the
pocket of his jacket.
31. A short time later, VAUGHN arrived. In reference to the liquor legislation, Son
asked VAUGHN, "Did 305 get out of ECM?" VAUGHN said it was not done yet and that the
alcohol committee would vote on Monday. Son asked VAUGHN ifhe was "fine" with it.
VAUGHN responded, "305? Shit, I don't know. Maybe." Son advised VAUGHN, "You did
your part. I mean, you know we need that for the Koreans." Later in the conversation, they then
discussed other liquor legislation, and VAUGHN stated that he was going to "fuck with 305
until [another bill] gets out."
32. At some point during the meeting at the restaurant, Son departed, leaving
VAUGHN to talk directly with CHS-7. CHS-7 told VAUGHN, "I shook the trees. So I got a
couple grand. If, if 305 gets through ... we got five more." VAUGHN replied "Okay." CHS-7
advised, "I got a couple right now." VAUGHN replied "Okay." CHS-7 stated, "I don't know if
9
you want me to give it right now." VAUGHN responded, "That's fine. Ain't anybody in here.
I appreciate it, man .... You keep doing your thing. I'm gonna keep doing mine." VAUGHN
said, "305 is going to come out but you know sometimes you golla send 'em a message. You
keep fucking with my shit. I'm not going to kill it."
33. VAUGHN then stated, "Moving forward man. I mean. We're halfway through
the session ... so anything else you might, you know, come across, that I can assist you, you
know, not to rush you, but we need to go ahead .... " VAUGHN then told CHS-7 about
campaign contributions another public official received, explaining:
... [l]f you get the right prosecutor, so you see a connection
between donation and legislator, and there's a connection between
legislator and legislation for that guy [poking table for emphasis], I
mean, I'm no rocket scientist ... that's what I'm saying, they put
the address on there, so ... I mean, I've seen mother fuckers go
down for less shit than that. But, I mean, I think that alone, that is a
direct connect, you can connect the dots easily there. Money to here,
then legislation for him. I mean, c'mon, I think I can sell that case,
and I ain't a lawyer [chuckling].
34. Within seconds after this part of the conversation, CHS-7 asked VAUGHN to
"keep an eye out for them." VAUGHN replied, "We cooL" CHS-7 stated, "Alright ... here you
go man," while handing VAUGHN $2,000 in cash. VAUGHN advised, "Appreciate it.
Appreciate it." CHS-7 stated, "So once 305 ... I'll circle back." VAUGHN said, "So they will
be voting on Monday. And unless ... like I said I was going to fuckwith it. But I'm gonnajust
... I'm gonna lay down .... So I'm not going to say nothing .... I kinda got [another elected
official] on alert. [The other elected official]'s looking too. So I ask [the other elected official]
to just lay down."
10
35. On March II, 2016, VAUGHN placed an outgoing phone call to Son. During the
call, VAUGHN told Son that the rest of the liquor bills, including PO 305-16, would be voted
out that coming Monday.
36. On March 15, 2016, PO 305-16 passed the House Economic Matters Committee,
with VAUGHN voting in favor. PO 305-16 unanimously passed the full House on March 17,
2016. The Senate passed PO 305-16 on April I I, 2016.
37. On April 12, 2016, VAUGHN met with CHS-7 at a restaurant in College Park,
Maryland, in order to collect the additional $5,000 in bribe money that was discussed at the
meeting on February 26,2016. At this meeting, CHS-7 paid VAUGHN $5,000 in exchange for
VAUGHN's support for, and the eventual passage of, PO 305-16.
38. On April 26, 2016, PO 305-16 was signed into law by the Oovemor of Maryland.
The Conspiracv and its Objects
39. From in or about January 2015 through in or about April 2016, the defendant,
MICHAEL LYNN VAUGHN,
did knowingly conspire, confederate, and agree with Son and others to commit offenses against
the United States, that is, being an agent of the State of Maryland, to corruptly solicit and
demand for the benefit ofa person, and accept and agree to accept, a thing of value from a
person, intending to be influenced and rewarded in connection with a business, transaction, and
series of transactions of the State of Maryland involving $5,000 or more, in violation of 18
U.S.c. S 666(a)(1 )(8).
II
Purposc of thc Conspiracy
40. It was a purpose of the conspiracy for VAUGHN to obtain things of value-
including but not limited to money-in exchange for VAUGHN performing and agreeing to
perform favorable official action for, and to use his influence on behalf of, business persons,
including Paig and Lec.
41. It was a further purpose of the conspiracy that in exchange for receiving things of
value, VAUGHN performed and agreed to perform favorable official action for, and to use his
influence on behalf of, business persons, including Paig and Lcc.
Manner and Mcans
42. The conspiracy was carried out through the following manner and means,
among others:
a. VAUGHN solicited things of value, including but not limited to money,
from Son, Paig, Lce, and CHS- 7.
b. VAUGHN accepted things of value, including but not limited to money,
from Son, Paig, Lce, and CHS-7.
c. In exchange for things of value, VAUGHN provided and agreed to
provide favorable official action for, and to use his influence on behalf of, business persons,
including Paig and Lcc.
Overt Acts
43. In furtherance of the conspiracy and to achieve its purposes, VAUGHN and his
co-conspirators committed the following overt acts, among others, in the District of Maryland
and elsewhere:
a. In or about April 2015, VAUGHN accepted $2,000 in U.S. currency from
Lec.
12
b. On or about October 21,2015, Son solicited $2,000 in U.S. currency from
Paig and Lee, on behalf of VAUGHN.
c. On or about November 10,2015, VAUGHN accepted $4,000 in U.S.
currency from Paig, which sum was paid on behalf of Paig and Lee.
d. On or about February 26,2016, VAUGHN accepted $2,000 in U.S.
currency from CHS- 7, as arranged and approved by SOR.
18 U.S.c. S 371
13
COUNTS TWO THROUGH FIVE

(Bribery Involving Agent of a Program Receiving Federal Funds)
The Grand Jury for the District of Maryland further charges that:
1. Paragraphs 1 through 38 and 40 through 43 of Count One are incorporated here.
2. On or about the following dates, in the District of Maryland and elsewhere, the
defendant,
being an agent of the State of Maryland, a State government that received federal benefits in
excess of $10,000 in the one-year periods beginning October I, 2014, and ending September 30,
2015, and beginning October 1, 2015, and ending September 30,2016, did corruptly solicit and
demand for the benefit of a person, and accept and agree to accept, a thing of value from a
person, intending to be inl1uenced and rewarded in connection with a business, transaction, and
series of transactions of the State involving $5,000 or more, to wit:
Count Date Event

VAUGHN accepted $2,000 in U.S.
2 April 2015
currency from Lee.

3 November 10, 20 IS currency from Paig, which sum was
paid on behalf of Paig and Lee.
4 February 26, 2016 currency from CHS-7, as arranged and
approved by Son.
S April 12, 2016
currency from CHS-7.
18 u.s.c. S 666(a)(1 )(B)
14
COUNTS SIX THROUGH EIGHT

(Wire Fraud)
The Grand Jury for the District of Maryland further charges that:
Introduction
At all times relevant to this Indictment:
I. Paragraphs I through 38 and 40 through 43 of Count One are incorporated here.
2. Under Maryland Code, Election Law, S 13-202, all campaign finance activity for
an election for a state office must be conducted through a political committee.
3. Under Maryland Code, Election Law, S 13-207, in order to establish a political
committee, a chairman and treasurer must be appointed in a manner prescribed by state law.
Under Maryland Code, Election Law, S 13-215, the candidate being promoted by the political
committee is prohibited from acting as the committee's treasurer. Under Maryland Code,
Election Law, S 13-218, the campai~,'n treasurer was responsible for maintaining the assets of the
political committee. Similarly, under S 13-218(b), the political committee's assets "may be
disbursed only if they have passed through the hands of the treasurer" and only "in accordance
with the purposes of the entity." Accordingly, a candidate, such as VAUGHN, was prohibited
from personally making disbursements from a political committee established to promote his
candidacy.
4. Under Maryland Code S 13-220, a campaign finance entity "shall deposit all
funds received in a designated campaign account" and, subject to certain exceptions inapplicable
to the conduct described herein, may only make disbursements from its bank account by check or
electronic method-that is, specifically 110/ by cash withdrawal.
5. Under Maryland Code, Election Law, S 13-221, the treasurer "shall keep a
detailed and accurate account book of all assets received, expenditures made, and obligations
15
incurred by or on behalf of the entity," and "[ eJach expenditure made from a campaign account
shal1 be supported by a receipt." Under Maryland Code, Election Law, ~ 13-304, each political
committee shall file a campaib'll finance report with the Maryland State Board of Elections at
specific times. The campaign finance report must include information regarding all
contributions and expenditures, and must be signed by the political committee's treasurer under
penalty of perjury.
6. The Maryland State Board of Elections maintained for public inspection the
campaign finance reports for political committees promoting candidates for state office.
7. The "Friends of Michael Vaughn" (hereinafter, "FOMV") candidate committee
was the name of the campaign finance entity for the VAUGHN campaign for Maryland State
Delegate from the date of its establishment in March 2002 through the present. FOMV was
subject to the Maryland state laws concerning political committees. FOMV's designated bank
account was account x9351 at Capital One Bank, a financial institution insured by the Federal
Deposit Insurance Corporation (hereinafter, "the FOMV account"). VAUGHN and the FOMV
political committee treasurer were the two signatories on the FOMV account.
The Scheme to Defraud
8. From in or about 2012 through in or about 2016, in the District of Maryland and
elsewhere, VAUGHN knowingly devised and intended to devise a scheme and artifice to
defraud FOMV and thc campaign contributors of FOMV, and obtain money and property by
means ofmaterial1y false and fraudulent pretenses, representations, and promises, with the intent
to defraud and knowledge of the scheme's fraudulent nature ("the scheme to defraud").
16
Manner and Means of the Scheme to Defraud
9. It was a part of the scheme to defraud that VAUGHN would solicit campaign
funds on the representations and premise that the funds would be used to facilitate his re-election
and maintain his leadership positions within the Maryland General Assembly.
10. It was further a part of the scheme to defraud that VAUGHN would deposit
checks from campaign contributors into the FOMV account at Capital One Bank branches in
Maryland.
II. It was further a part of the scheme to defraud that VAUGHN would withdraw
campaign funds from the FOMV account to use for personal expenses, including electronically
transferring money from the FOMV campaign account directly to VAUGHN's personal bank
account, making payments to his personal American Express credit card account, and making
payments of his personal income tax to the Internal Revenue Service.
12. It was further a part of the scheme to defraud that VAUGHN would receive
campaign contributions, deposit them into the FOMV account, and then convert them to his
personal use without identifying the contributions on campaign finance reports made to the
Maryland State Board of Elections. For example, from June 10,2015, through November 10,
20 15, at least 25 checks totaling approximately $11,175, were deposited into the FOMV account
but not reported on the FOMV campaign finance report. As with the other amounts deposited
into the FOMV account, the funds from these checks were then withdrawn by VAUGHN and
converted for his personal use.
13. It was further a part of the scheme to defraud that VAUGHN would cause the
filing of fraudulent campaign finance reports with the Maryland State Board of Elections in order
to conceal the scheme to defraud from FOMV and the FOMV campaign contributors. For
17
example, as of January 14,2015, the campai~'Il finance report filed with the Maryland State
Board of Elections showed a balance in the FOMV account of $64,462.44. The expenditures
identified in the report did not include substantial cash withdrawals made by VAUGHN. The
FOMV's account actual balance on that date, according to bank statements, was only $1 ,654.36.
14. It was further a part of the scheme to defraud that VAUGHN would make and
cause to be made false representations to FOMV, and would make and cause to be made false
records within FOMV.
The Charge
IS. On or about each date listed below, in the District of Maryland and elsewhere,
VAUGHN, for the purpose of executing and attempting to execute the scheme to defraud, did
knowingly and willfully transmit and cause to be transmitted by means of wire communication,
in interstate and foreign commerce, writings, signs, signals, pictures, and sounds, to wit,
VAUGHN transmitted and caused to be transmitted the following:
Count Date Event

A wire communication sent outside of
6 November 21, 2013 Maryland regarding a $1,900 cash
withdrawal from the FOMV account
7 December 8,2014 Maryland regarding a $1,100 cash
8 July 9, 2015 Maryland regarding a $3,000 cash
18 U.S.C. S 1343
18
FORFEITURE ALLEGATION
The Grand Jury for the District of Maryland further finds that:
1. Pursuant to Federal Rule of Criminal Procedure 32.2, notice is hereby given to the
defendant that the United States will seek forfeiture as part of any sentence in accordance with
18 U.S.c. ~ 98 I(a)(l)(C) and 28 U.S.c. ~ 2461(c), in the event of the defendant's convictions
under Counts One through Eight of this Indictment.
2. As a result of the offenses alleged in Counts One through Eight, the defendant,
shall forfeit to the United States any property, real and personal, which constitutes and is derived
from proceeds traceable to the violations.
Substitute Assets
3. If, as a result of any act or omission of the defendant, any proceeds subject to
forfeiture:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property that cannot be subdivided without
difficulty,
19
it is the intent of the United States, pursuant to 21 u.s.c. 9 853(P) to seek forfeiture of any other
property of said defendant.
18 u.s.c. 9981(a)(l)(C)
21 u.s.c 9 853
28 u.s.c. 92461(c)
rz.rl .::r.
Rod J. Rosenstein
KJW1s1M'n!if})
United States Attorney
A TRUE BILL:
SIGNATURE REDACTED
Date:.3/ Co W----
Foreperson
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Michael Lynn Vaughn Indictment

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Michael Lynn Vaughn Indictment

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Case 8:17-cr-00125-PX Document 1 Filed 03/06/17 Page 1 of 20

\j.P T/,WI~lSKJAGR: USAO 2017ROOl47

IN THE UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA *

The Grand Jury for the District of Maryland charges that:

At all times relevant to this Indictment;

Marvland State Governmellf

with 141 Delegates.

subsidy, loan guarantee, insurance, and other fonn of Federal assistance.

Maryland Code, Criminal Law, S 9-20 I.

office to file annual financial disclosure statements.

5. The Maryland State Ethics Commission, as directed in Maryland Code, General

6. The defendant, MICHAEL LYNN VAUGHN ("VAUGHN"), was a Maryland

was a member of the Economic Matters Committee.

Other Organizations and Persons

Maryland to serve as a commissioner on the Prince George's County Board of License

as its Chief Liquor Inspector.

George's County, Maryland.

relationship with Son.

Marvland State Legislation

on April 14, 2015.

Details of the Pav-to-Play Bribery Conspiracy

The Earlv 2015 Bribe Pavmen/

The November 2015 Bribe Pavmen/

the bribe payment to VAUGHN.

exchange for his official assistance.

they are "putting a down payment on it."

were still standing at the front entrance of the restaurant.

The Februarv 2016 and April 2016 Bribe Pavmenls

businesses from competition.

and try to change something."

would add licenses to circumvent the system.

25. On February 3, 20 16, VAUGHN contacted other Maryland legislators in an effort

would effectively limit future competition for Paig and Lee.

loving your ass."

pocket of his jacket.

until [another bill] gets out."

keep fucking with my shit. I'm not going to kill it."

campaign contributions another public official received, explaining:

to just lay down."

out that coming Monday.

2016. The Senate passed PO 305-16 on April I I, 2016.

VAUGHN's support for, and the eventual passage of, PO 305-16.

The Conspiracv and its Objects

MICHAEL LYNN VAUGHN,

series of transactions of the State of Maryland involving $5,000 or more, in violation of 18

U.S.c. S 666(a)(1 )(8).

Purposc of thc Conspiracy

including Paig and Lec.

influence on behalf of, business persons, including Paig and Lcc.

Manner and Mcans

a. VAUGHN solicited things of value, including but not limited to money,

from Son, Paig, Lce, and CHS- 7.

b. VAUGHN accepted things of value, including but not limited to money,

from Son, Paig, Lce, and CHS-7.

c. In exchange for things of value, VAUGHN provided and agreed to

including Paig and Lcc.

a. In or about April 2015, VAUGHN accepted $2,000 in U.S. currency from

b. On or about October 21,2015, Son solicited $2,000 in U.S. currency from

Paig and Lee, on behalf of VAUGHN.

c. On or about November 10,2015, VAUGHN accepted $4,000 in U.S.

d. On or about February 26,2016, VAUGHN accepted $2,000 in U.S.

currency from CHS- 7, as arranged and approved by SOR.

COUNTS TWO THROUGH FIVE