wee raaunon 10 ul 12 1B 14 15 16 7 18 19 20 21 2 23 24 25 26 27 28 UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, CR O1-_ 00K fe. Plaintiff, INFORMATION v. [18U.S.C;§ 371: Congpiracy - to Defraud the United States: JAMES TIAHAJA RIADY, 2US.C. §44le, 4418, 437g: LIPPOBANK CALIFORNIA, a California Illegal Campaign Contributions} chartered bank, Defendants, The United States Department of Justice charges: 1 M uy u MW 1 u " DOR. gee a aw se 10 u 12 1B 14 15 16 7 18 19 20 21 22 23 24 25 6 27 28 GEN) LLEGATIONS At all times relevant to this Information: A. Federal Election Laws 1. The Federal Election Campaign Act (“FECA”) governed contributions to candidates, their campaign committees, and political committees in United States elections. 2, FECA required that federal candidates for public office designate a principal campaign committee to solicit, accept, and receive contributions and to make expenditures for the campaign. FECA also permitted the establishment of other political committees which could solicit, accept, and receive contributions and to make expenditures for candidates and political parties, Under FECA, political committees received contributions as an agent of a candidate, candidates, and/or a political party. 3. FECA required that each treasurer of a political committee that participated in federal elections file periodic reports to the Federal Election Commission (“FEC”) identifying contributors by name, address, and occupation and the contributions provided by those contributors by date and amourt. 4, FECA prohibited the following: a, Individuals making contributions in excess of $1,000 to any candidate and his authorized political committees with respect to any election for federal office; in excess of $20,000 to the political committees established and maintained by a nation political party in any calendar year, in excess of $5,000 to any other political committee in any calendar year; or in excess of $25,000 for the purpose of influencing elections for federal office in any calendar year. b. Corporations making contributions in connection with any election for federal office; ¢. Individuals who are neither citizens of the United States nor permanent residents of the United States, foreign corporations, foreign partnerships, foreign associations, or foreign organizations making contributions, directly or through any otherperson, in connection with an election to any political office or in connection with any primary election, convention, or caucus held to select candidates for any political office; 4. Contributions in the name of another or using one name to effect a contribution by another in connection with any election for federal office, including the making contributions through conduits; €. Cash contributions in excess of $100 in connection with any election for federal office. 5, The FEC was an agency of the United States government, headquartered in Washington D.C., and entrusted with the responsibility of enforcing the reporting requirements of the FECA, making those reports available to the public, investigating and instituting civil enforcement actions with respect to violations of the FECA, and referring such violations to the Department of Justice for possible criminal prosecution. B. Parties and Entities 6. Lipo Group was an unincorporated asso: iation of banking, financial services, manufacturing, real estate, and commercial companies primarily based in Indonesia and owned by the Riady family of Indonesia. Lippo Group consisted of numerous corporations, partnerships, and other corporate entities, including Grenadines, Ltd., Victor Right, Ltd., B.O.T. Corporation, N.V.., Hip Hing Holdings, Inc., Toy Center Holdings of California, Inc., San Jose Holdings, Inc., the Hong Kong Chinese Bank, LippoBank (Jakarta), and defendant LIPPOBANK CALIFORNIA. 7. Grenadines, Ltd. was a Hong Kong partnership. 8. Victor Right, Ltd. was a foreign partnership. 9, B.O.T. Corporation, N.V. (“BOT”) was a Netherlands Antilles corporation, 10, Hip Hing Holdings, Inc. (“HHH”) was a California corporation engaged in the development of properties located in Los Angeles, California, 11, Toy Center Holdings of California, Inc. (“TCH”) was a California corporation ‘engaged in the development of a parcel of property located in Los Angeles, California,ROE eo) a) cont fe coy 10 12 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 12, San Jose Holdings, Inc, (“SIH”) was a California corporation engaged in the development of a parcel of property located in San Jose, California. 13, The Hong Kong Chinese Bank (“HKCB”) was a banking establishment with its principal place of business located in Hong Kong. 14, Bank Central Asia (“BCA”) was a banking establishment headquartered in Jakarta, Indonesia with branch offices located in New York, New York. 15, LippoBank (Jakarta) was a banking establishment headquartered in Jakarta, Indonesia. 16. Defendant LIPPOBANK CALIFORNIA (“defendant LIPPOBANK”) was a banking establishment chartered in the State of California, with offices located in Los Angeles, San Francisco, San Jose, and Westminster, California. Prior to 1990, defendant LIPPOBANK was known as the Bank of Trade. 17. Defendant JAMES TIAHAJA RIADY (“defendant RIADY”) was born in, and was a citizen of, Indonesia. On or about November 18, 1987, defendant RIADY was granted status as a lawful permanent resident of the United States, Sometime in 1993, defendant RIADY surrendered his status as a lawful permanent resident of the United States 18, Defendant RIADY was an Executive Director of Lippo Group and, at various times, an officer or director of numerous corporate entities affiliated with Lippo Group (collectively “Lippo entities”), including BOT, the HKCB, HHH, TCH, and SIH. For the period 1986 through 1989, defendant RIADY was chief executive officer, a member of the board of directors, and an approximate 98 percent shareholder of defendant LIPPOBANK. 19, John Huang (“Huang”) was an officer and director of various Lippo Group corporate entities, During the period 1986 through 1988, Huang was president of defendant LIPPOBANK. During the period 1988 through 1989, Huang was senior vice-president of BCA. During the period 1990 through 1994, Huang was vice-president of HHH, TCH and SJH and vice-chairman of the board of directors for defendant LIPPOBANK.1] C. Purpose of Contributions 2 20. Beginning in or about December 1987, defendant RIADY and Huang either made, 3 | solicited, or otherwise caused to be made campaign contributions to various candidates for 4|| political office in the United States. 5 21. By making, soliciting, or otherwise causing contributions to be made, defendant ¢ | RIADY, Huang, and others sought to obtain, inter alia, benefits from the various campaign 7 | committees and candidates, including 7 a. access, meetings, and time with politicians, elected officials, and other . high-level government officials; 0 b. contacts and status for Lippo Group and defendant LIPPOBANK with _ business and government leaders in the United States and abroad; 2 ¢. business opportunities for Lippo Group and defendant LIPPOBANK by im virtue of the referenced contacts; ul 4. government policies which would inure to the benefit of Lippo Group and defendant LIPPOBANK, including MFN status for China, open trade policies with e Indonesia, normalization of relations with Vietnam, Community Reinvestment Act 6 exemptions for defendant LIPPOBANK, a repeal of the Glass-Steagall Act which limited 2 business opportunities for defendant LIPPOBANK, and a relaxation of Taiwanese 8 restrictions on investment by foreign banks; - e. the deposit of funds into defendant LIPPOBANK by political campaign 2 committees and government agencies; and 21 £ local government support for Lippo Group’s California property 2 development projects which would in turn benefit defendant LIPPOBANK’s plans for 23 expansion, 24 22. In April 1988, shortly after a fundraiser at his home, defendant RIADY issued 25 } letters to various United States Senators which urged a repeal the Glass/Steagall Act, pressure on 26 | Taiwan to eliminate its restrictions on investment by foreign banks, and for the Senators to travel 27 28 5Ron Seem ra.dau u 12 1B 14 15 16 7 18 19 20 21 22 24 25 26 27 28 to Indonesia, Taiwan, and Hong Kong to meet with Asian bankers. 23, InMarch 1993, shortly after the inauguration of President Bill Clinton, Huang sent to President Clinton and Vice-President Al Gore a letter from Mochtar Riady, the father of defendant RIADY, which discussed economic policy issues, including most-favored nation status for China, normalizing relations with Vietnam, and inviting President Suharto of Indonesia to the G-7 meeting in Tokyo during the summer of 1993. D. Incorporatio1 Reference 24, These General Allegations are incorporated by reference in each and every count of this Information.oA wera 10 ul 12 13 14 15 16 ” 18 19 20 a 22 2 24 28 26 27 28 COUNT ONE [18 U.S.C. § 371] A. — Object Of The Conspiracy 25. Beginning in or about May 1990 and continuing to in or about June 1994, in Los Angeles County, within the Central District of California and elsewhere, defendant JAMES RIADY, John Huang, and others known and unknown, knowingly and willfully conspired and agreed to defraud the United States, by impairing, obstructing, and defeating the lawful functions and duties of the FEC, through deceitful and dishonest means, in violation of Title 18, United States Code, Section 371 B, Means Of The Conspiracy 26. The object of the conspiracy was to be accomplished through the reimbursement of political campaign contributions, with funds often obtained from foreign individuals and entities which were prohibited sources under the FECA and often in violation of the dollar limitations established by the FECA. The object of the conspiracy was implemented through at least five mechanisms The Kong Bank Account Reimburs fay 1990 ul 27. — Huang would make contributions to various political campaign committees. 28, Huang would solicit political contributions from officers and employees of defendant LIPPOBANK. 29. The officers and employees of defendant LIPPOBANK would make contributions to various political campaign committees in accordance with the directions of Huang. 30. Huang would reimburse the officers and employees of defendant LIPPOBANK either by cash or by personal check drawn from accounts he maintained at defendant LIPPOBANK. 31. Huang would request that defendant RIADY reimburse Huang’s political contributions, the political contributions Huang had reimbursed, and various business expenses and community contributions Huang had made,Ce aa ws 10 u 12 13 14 15 16 7 18 19 20 2 22 23 24 25 26 27 28 32, Defendant RIADY would cause the political contributions, community contributions, and business expenses to be reimbursed by instructing a Lippo Group executive to honor Huang’s requests for reimbursement. 33. A Lippo Group executive would reimburse Huang these political contributions, community contributions, and business expenses, by causing money to be wired from a foreign Lippo Group entity to an overseas account maintained by Huang at the Hong Kong Chinese Bank. The Tl 1992 - September 1993) 34. Defendant RIADY and Huang would agree that Lippo Group entities operating in the United States would make non-federal contributions. 35. Huang would issue checks on behalf of HHH, TCH, and SJH to various political campaign committees. 36. Huang would request reimbursement for all business expenses incurred by HHH, ‘TCH, and SJH in the United States, including the political contributions. 37. ALLippo Group executive would reimburse HHH, TCH, and SH for these business expenses and contributions, by causing money to be wired from Grenadines, Ltd. and Victor Right, Ltd. to accounts maintained by HHH, TCH, and SJH at defendant LIPPOBANK. sh Advances 1992 - October 1992 38. Defendant RIADY would pledge $1 million in support of Arkansas Governor Bill Clinton’s campaign for the Presidency of the United States, 39. Defendant RIADY would encourage Huang to make contributions and solicit contributions from officers and employees of defendant LIPPOBANK and other Lippo Group entities, Defendant RIADY would also encourage Huang to travel to political events leading up to the November 1992 election to demonstrate support for candidate Clinton’s campaign. 40. Defendant RIADY would advance reimbursements to Huang for contributions and political travel by causing funds to be wired from a foreign Lippo Group entity to his personal checking account maintained at defendant LIPPOBANK, writing checks to cash, and providingCe a awe 10 ul 12 13 4 15 16 7 18 19 20 ai 22 23 24 28 26 27 28 the cash to Huang, 41. Huang would make contributions to various political campaign committees, 42. Huang would solicit political contributions from officers and employees of defendant LIPPOBANK and other Lippo entities. 43, The officers and employees of defendant LIPPOBANK and other Lippo Group entities would make contributions to various political campaign committees in accordance with the directions of Huang, 44, Huang would reimburse the officers and employees of defendant LIPPOBANK either by cash he had received from defendant RIADY or by personal check drawn from accounts he maintained at defendant LIPPOBANK. Reimburser jober 1992 - May 1994) 45. Defendant RIADY and Huang would jointly identify executives affiliated with Group E Lippo Group and defendant LIPPOBANK (the “Executives”) who were either citizens or permanent residents of the United States and thus legally eligible to contribute to political campaigns. 46. Huang would solicit the Executives and their spouses to make contributions to various political campaign committees. 47. The Executives and their spouses would make contributions to various political campaign committees in accordance with the directions of Huang. 48. A Lippo Group executive would reimburse the contributions of at least one of the Executives and their spouses by handing the Executive cash. the Purported “Bonuses” (January 199: 1994) 49. Huang would continue making contributions and continue soliciting, obtaining, and reimbursing contributions from officers and employees of defendant LIPPOBANK and other Lippo Group entities. 50. Defendant RIADY would reimburse Huang’s contributions and contributions Huang had reimbursed by causing HHH to issue Huang a “bonus” which would be equal to theGece Sl ong oe 10 u 12 13 14 15 16 7 18 19 20 21 22 23 24 25 6 27 28 amount to be reimbursed plus any taxes or other payroll deductions that would have to be deducted from a true bonus. For the 1992 calendar year, the “bonus” would include a true bonus of $30,000; the remainder of the “bonus” would be designed to reimburse Huang for political contributions, as well as community or charitable contributions Huang had made or reimbursed. 51. More specifically, Huang would request that defendant RIADY reimburse Huang’s political contributions, the political contributions Huang had reimbursed, and various community or charitable contributions Huang had made for a specific calendar year. For the calendar year 1992, Huang would deduct from his tally the cash advances provided by defendant RIADY for the period August through October 1992. 52, Defendant RIADY caused funds to be wired from Grenadines, Ltd. and Victor Right, Ltd, to an account maintained by HHH at LIPPOBANK. 53. The corporate controller of HHH would enter into HHH’s accounting ledgers a “ponus” for Huang, deduct payroll taxes and related employee deductions from the bonus, and issue a check to Huang for the remaining amount. C. Overt Acts - 54, In furtherance of the conspiracy and to accomplish the objects of the conspiracy, defendant JAMES RIADY and other members of the conspiracy committed various overt acts within the Central District of California, and elsewhere, including, but not limited to, the following: : 55, Onor about May 8, 1990, defendant RIADY caused Huang to be reimbursed for $74,326.30 in political contributions and community contributions made during the period 1988 through May 1990 which was realized in a wire transfer from a foreign Lippo Group entity to Huang’s HKCB account. 56. — Onor about November 15, 1990, defendant RIADY caused Huang to be reimbursed for $23,120.54 in political contributions and community contributions made during the period May 1990 through November 1990 which was realized in a wire transfer from a foreign Lippo Group entity to Huang’s HKCB account, 10© we a aw ae 10 ul 12 B 14 1s 16 7 18 19 20 21 22 23 25 26 27 28 57. Onor about July 31, 1991, defendant RIADY caused Huang to be reimbursed for $13,136.50 in political contributions and community contributions made during the period November 1990 through July 1991 which was realized in a wire transfer from a foreign Lippo Group entity to Huang’s HKCB account, 58. Onor about August 19, 1992, defendant RIADY caused $9000 to be wired from a foreign Lippo Group entity to his account at defendant LIPPOBANK. 59, Onor about August 21, 1992, defendant RIADY instructed his secretary to prepare a $5000 check made payable to cash, dated August 24, 1992, and drawn on his account at defendant LIPPOBANK. 60. Onor about October 1992, a Lippo Group executive handed Joseph Sund, one of the Executives, approximately $20,000 in cash to reimburse Sund for contributions to the ‘Arkansas State Democratic Party, the Michigan State Democratic Party, and the Democratic National Committee Victory Fund. 61. — Onor about February 1, 1993, defendant RIADY caused $200,000 to be wired from a foreign Lippo entity to the account of HHH at defendant LIPPOBANK to fund a bonus for Huang, 62. On or about September 12, 1993, Huang sent a facsimile memorandum to Jakarta, Indonesia regarding the reimbursement of $67,000 in expenses incurred by HHH, which included $2500 contribution to the Democratic National Committee for the campaign of Michael Woo for Los Angeles mayor. 63. — Onor about October 15, 1993, Huang requested that $15,000 to be wired from a foreign Lippo entity to the account of HHH at defendant LIPPOBANK to reimburse a $15,000 HHH contribution to the Democratic National Committee. 64. Onor about October 15, 1993, Huang requested that $30,000 to be wired from a foreign Lippo Group entity to the account of BOT at defendant LIPPOBANK to reimburse $15,000 contributions from TCH and SJH to the Democratic National Committee 65. Onor about February 3, 1994, defendant RIADY caused $230,000 to be wired ulaaweorn 10 uw 12 13 14 15 16 7 18 19 20 21 22 23 24 25 27 28 from a foreign Lippo entity to the account of HHH at defendant LIPPOBANK to fund a bonus for Huang, D. Incorporation By Reference 66. The allegations of the Conspiracy count are incorporated by reference in each an every count of this Information. 12wa ew we ao 10 u 12 13 14 15 16 17 18 19 20 2 22 23 25 26 27 28 COUNTS TWO THROUGH EIGHTY-SEVEN [2 US.C. §44le, 441f, 437g] ‘On or about the following dates, in Los Angeles County, within the Central District of California, and elsewhere, defendant LIPPOBANK CALIFORNIA, through its agents, knowingly and willfully caused the following contributions to be made jolation of the FECA prohibition against foreign and conduit contributions to United States elections, said contributions aggregating $2,000 or more during the referenced calendar year: Count Date Committee Amount TWO 4/25/88 DSCC $10,000 THREE 5/19/88 Dukakis for President $500 FOUR 9/18/88 Citizens for $.B. Woo $2000 FIVE 118/88 Jim Billbray for Congress $500 six 6/10/89, Citizens for Joe Kennedy $250 SEVEN 8/1/89 McConnell for Senate $1000 EIGHT 9/10/89 California Democratic Party $1000 NINE 9/27/89 DSCC $5000 TEN 10/10/89 DSCC $5000 ELEVEN 11/16/89 Berman for Congress. $800 TWELVE 11/28/89 Friends of Howell Heflin $1000 THIRTEEN 12/11/89 Friends of Senator Carl Levin $1000 FOURTEEN 2/24/90 ‘Nancy Pelosi for Congress $1000 FIFTEEN 3/5/90 Mel Levine for Congress $1000 SIXTEEN 4/2/90 Cranston for Senate $500 SEVENTEEN 6/19/90 Kerry for Senate in 90 3500 EIGHTEEN 7116/90 pecc $2000 ‘NINETEEN 8/21/90 Simon for Senate $600 13 Conduit J. Huang J. Huang J. Huang J. Huang, J. Huang J. Huang J. Huang J. Huang J. Huang J. Huang J. Huang J. Huang, J. Huang, J. Huang J. Huang J. Huang J. Huang J. Huangv Cem aan ae 10 1 12 13 14 15 16 17 18 19 20 21 2 23 25 26 27 28 Count TWENTY TWENTY-ONE TWENTY-TWO TWENTY-THREE, TWENTY-FOUR TWENTY-FIVE TWENTY-SIX TWENTY-SEVEN TWENTY-EIGHT TWENTY-NINE THIRTY THIRTY-ONE THIRTY-TWO THIRTY-THREE THIRTY-FOUR THIRTY-FIVE THIRTY-SIX THIRTY-SEVEN THIRTY-EIGHT THIRTY-NINE_ FORTY FORTY-ONE, FORTY-TWO FORTY-THREE, FORTY-FOUR FORTY-FIVE Date 8/24/90 10/13/90 10/20/90 43/91 Ss/V/91 6/26/91 121/92 3/24/92 3/27/92 5/26/92 7131/92 8/3/92 8/24/92 9/8/92 9/23/92 9/24/92 9/25/92 9/30/92 9/30/92 9/30/92 10/1/92 10/6/92 10/9/92 10/19/92 10/26/92 11/12/92 Committee Amount Friends of Harry Reid $500 DNC $1000 Conrad Campaign $1000 Mikulski for U.S. Senate $500 People Supporting T Daschle $1000 Gray Davis for U.S. Senate $500 Clinton for President $500 Friends of Edward Kennedy $1000 Al Lum for Congress $500 ‘McCarthy for Senate $1000 Friends of Senator D’Amato $500 DNC $5000 DNC $5000 CDP Victory Fund 92 $5000 ‘Arkansas Democratic Party $5000 DNC Victory Fund $10,000 DNC Victory Fund $5000 Michigan Democratic Party $5000 McCarthy for Senate $1000 CDP United Campaign Fund $1000 DNC Victory Fund $2000 Mark Takano for Congress $500 Gloria Ochoa for Congress $500 P. Garamendi for Congress $250 Friends of Kent Conrad $1000 DSCC $1000 14 Conduit J. Huang J. Huang J. Huang J. Huang J. Huang J. Huang J. Huang J, Huang, J. Huang J, Huang J. Huang J, Huang J, Huang J, Huang J. Sund J. Sund J, Huang J. Sund ‘A. Setiawan J. Huang S. Widjaja J. Huang J, Huang J. Huang S. Widjaja J. Huang© we a auneen ir 12 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 Count FORTY-SIX FORTY-SEVEN FORTY-EIGHT FORTY-NINE FIFTY FIFTY-ONE FIFTY-TWO FIFTY-THREE FIFTY-FOUR FIFTY-FIVE FIFTY-SIX FIFTY-SEVEN FIFTY-EIGHT FIFTY-NINE SIXTY SIXTY-ONE SIXTY-TWO SIXTY-THREE SIXTY-FOUR SIXTY-FIVE SIXTY-SIX SIXTY-SEVEN SIXTY-EIGHT SIXTY-NINE SEVENTY SEVENTY-ONE Date 11/13/92 12/21/92 3/12/93 3/12/93 3/12/93 3/24/93 47193 47/93 47/93 5/1193 5/1/93 5/12/93 5/27/93 5/28/93 6/1/93 6/4/93 6/14/93 6/16/93 6/16/93 6/18/93 7/93 711193 111193 79193 8/2/93 8/16/93 Committee Fowler for Senate Kerry Committee Re-elect T. Kennedy Re-elect T. Kennedy Kennedy for Senate Hamilton for Congress Citizens for J. Kennedy Citizens for J. Kennedy Citizens for J. Kennedy Mitchell for Senate Simon for Senate Dscc Robb for Senate DNC Effective Government Robb for Senate Robb for Senate Effective Government Effective Government DSCC DNC Amount $1000 $500 $1000 $1000 $1000 $1000 $1000 $1000 $500 $1000 $500 $5000 $1000 $2500 $1000 $1000 $1000 $5000 $1000 $1000 $10,000 Citizens for Senator Wofford $1000 Ackerman for Congress Simon for Senate $500 $1000 Citizens for Senator Wofford $1000 Neil Dhillon for Congress 15 $500 Conduit J. Huang J. Huang J. Huang A. Setiawan S. Widjaja J, Huang J. Huang A. Setiawan S. Widjaja J, Huang J. Sund J. Huang J. Sund HHH S. Widjaja S. Widjaja ‘A. Setiawan J. Huang A. Setiawan J. Huang J, Huang J. Sund J. Sund J. Huang J. Huang J. Huang,1 2) 3 4 5 6 7 8 9 10 itt 12 13 4 15 16 7 18 19 20 2 22 23 24 25 26 27 28 Count SEVENTY-TWO SEVENTY-THREE SEVENTY-FOUR SEVENTY-FIVE SEVENTY-SIX SEVENTY-SEVEN SEVENTY-EIGHT SEVENTY-NINE EIGHTY EIGHTY-ONE EIGHTY-TWO EIGHTY-THREE, EIGHTY-FOUR EIGHTY-FIVE EIGHTY-SIX EIGHTY-SEVEN Date 9/23/93 9/27/93 9127193 9127193 10/25/93 11/5/93 11/22/93 11/27/93 12/1/93 12/2/93 12/2/93 12/10/93 12/17/93, 12/22/93 4n2/94 $/20/94 Committee Amount DNC $15,000 DNC $815,000 DNC $15,000 DNC $5000 Dscc $13,500 Berman for Congress $800 Gephardt in Congress $1000 Friends of Larry Pressler $1000 Ackerman for Congress $300 Friends of L. Pressler $1000 Friends of L, Pressler $500 Friends of Mark Takano $1000 DNC $25,000 Robb for Senate $1000 Effective Government $2500 California Victory 94 $5000 ROBERT J. CONRAD, JR, Conduit TCH SIH HHH J. Sund J. Huang J. Huang J. Huang J. Sund J. Huang, A. Setiawan S, Widjaja J. Huang J. Huang J. Huang, J, Sund J. Sund Chief, Campaign Financing Task Force DANIEL J. O'BRIEN Assistant United States Attorney Supervisory Attorney, ‘Campaign Financing Task Force 1610 1a 12 13 4 1s 16 a7 18 1g 20 21 22 23 24 25 76 a7 28 ROBERT J. CONRAD Chief, Campaign Financing Task Force " U.S. Department of Justice a DANIEL J. O'BRIEN (State Bar #141720) ~ Assistant United States Attorney ve ‘Supervisory Attomey, Campaign Financing Task Force U.S. Department of Justice '300 United States Courthouse . 312 North Spring Street — Los Angeles, California 90012 Telephone: (213) 894-2468 Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, ) CRO e002 p Plaintiff, PLEA AGREEMENT v. ) JAMES TIAJHAJA RIADY, } LIPPOBANK CALIFORNIA, } California chartered bank, Defendant. } ———— Plaintiff United States of America, through its attorney of record, hereby files the plea agreement with defendant James Tjahaja Riady in the above-referenced matter. Dated: January 11, 2001 Respectfully submitted, ROBERT J. CONRAD Chief, Campaign Financing Task Force US. Department of Justice LLADLE DANIEL], OBRIEN Assistant United States Attomey Supervisory Attorney, Campaign Financing Task Force USS. Department of Justice