2:17-cr-20363-SJM-RSW Doc#1 Filed 05/30/17 Pglof4 PgID1 a UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION UNI (ED STATES OF AMERICA, Case:2:17-cr-20363 Judge: Murphy, Stephen J. MJ: Whalen, R: Steven Filed: 05-30-2017 At 03:44 PM ee ] INFO USA V. MODI (LH) VIOLATIONS: 18 U.S.C. § 371 18 U.S.C. § 666(a) D-1 PAULIN MODI, Defendant. f INFORMATIO! The United States Attomey charges: COUNT ONE (18 U.S.C. §§ 371 & 666(a) — Bribery Conspiracy Concerning Programs Receiving Federal Funds) D-1_ PAULIN MODI THE CONSPIRACY 1. From in or about May 2014, through October 2014, in the Eastern District of Michigan, Southern Division, defendant PAULIN MODI, along with others, did unlawfully, willfully, and knowingly combine, conspire, confederate, and agree with each other to give, offer, and agree to give a thing of value to a public official of Washington Township Michigan (“Washington Township Off 1 ial A”), a2:17-cr-20363-SJM-RSW Doc#1 Filed 05/30/17 Pg2of4 PgID2 local governmental entity that received in excess of $10,000 in federal aid in 2014, with the intent to influence and reward Washington Township Official A in connection with a business, transaction, or series of transactions of Washington Township involving $5,000 or more, in violation of Title 18, United States Code, Section 666(a). MANNER AND MEANS BY WHICH THE CONSPIRACY WAS CARRIED OUT 2. It was part of the conspiracy that PAUL MODI would make cash bribe payments to Washington Township Official A, and facilitate payments to that official by a co-conspirator. OVERT ACTS In furtherance of the unlawful conspiracy, and to effect its objectives, the co- conspirators committed the following overt acts, among others: 3. On May 28, 2014, PAULIN MODI made a $1,000 cash payment to Washington Official A in order to influence that official with respect to MODI’s company’s contract with Washington Township. 4. Between June and October of 2014, PAULIN MODI helped facilitate a $2,000 cash bribe by a co-conspirator to Washington Township Official A, in order2:17-cr-20363-SJM-RSW Doc#1 Filed 05/30/17 Pg3of4 PgID3 to influence that official to award a contract. All in violation of Title 18, United States Code, Sections 371 and 666(a). DANIEL L. LEMISCH Acting United States Attorney WR. Michael Bullous R. MICHAEL BULLOTTA Assistant United States Attorney Dated: May 30, 2017 David A. Garde DAVID A. GARDEY Assistant United States Attorney Chief, Public Corruption Unit2:17-cr-20363-SJM-RSW Doc#1 Filed 05/30/17 Pg4of4 PgID4 Case:2:17-cr-20363 Judge: Murphy, Stephen J, i saa a , MJ: Whalen, R. Stever United States District Court 7 an Eastem Distnct ot Michigan Griminal Case Cover flee 05072017 a1 03.44 Pat MOD! (LH) NOTE: It's the responsibilty ofthe Assistant U.S Attorney signing this form to complot t accurately in all respects. = Taps] Companion Case Number: 16-20732 This may be a companion case based upon LCrR 87.10 (by(4)': | Judge Assigned: Robert H. Cleland Rives Ono AUSA’s Initials: —7 Case Title: USA v. D-1_ PAULIN MODI County where offense occurred : _Macomb Felony Cimisdemeanor Oretty Indictment__¥ Information — no prior complaint. Indictment Information based upon prior complaint (Case number: 1 Indictment____Information-— based upon Lerk 87.10 (4) [Complete Superseding section below] Superseding CaseiInformation 7 Superseding to Case No: Judge: [corrects errors; no additional charges or defendants Involves, for plea purposes, different charges or adds counts, Embraces same subject matter but adds the additional defendants or charges below: Defendant name Charges Prior Complaint (if applicable) Please take notice that the below listed Assistant United States Attorney Is the attorney of record the above captioned case. May 30, 2017 Date R. MICHAEL BULLOTIA Assistant United States Attomey 211 W. Fort Stroct, Suite 2001 Detroit, Ml 48226-3277 Phone:313-226-0507 Fax: 313-226-3413 E-Mail address: Michael Bullotta@usdoj.gov Attorney Bar #: 163401 (CA) 1 Companion cases are matters in which it appears that (1) substantially similar evidence will be offered at trial, or (2) the same or lated partios are present, and the cases arise out ofthe same transaction or occurrence. Cases may be companion cases even though one of them may have already been terminated. 5/16