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UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
October 2001 Grand Jury
UNITED STATES OF AMERICA, ))
Plaintiff, ))
v. ))
RICHARD JAMES MORAN, )GINA CHA MORAN, )RONALD ADAIR PARRISH, )RICHARD LEE CARLISLE, and )JOSEPH KANG HUR, )
))
Defendants. )))
)
NO. SA CR ________________
I N D I C T M E N T
[18 U.S.C. § 371: Conspiracy;18 U.S.C. § 201: Bribery; 18U.S.C. § 1956(h): MoneyLaundering Conspiracy; 18U.S.C. § 1957: Engaging inMonetary Transactions inProperty Derived from UnlawfulActivity; 41 U.S.C. § 423:Disclosure of ProcurementInformation; 18 U.S.C. § 1512:Obstruction of Justice; 18 U.S.C. § 2(a): Aiding andAbetting]
The Grand Jury charges:
INTRODUCTION
At all times relevant to this indictment:
1. The United States Army Contracting Command Korea ("USA-
CCK") had responsibility for solicitation, award and oversight of
contracts entered by the United States Armed Forces in the Republic
of Korea.
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2. Defendant RICHARD J. MORAN was a Colonel in the Eighth
United States Army and Commander of the USA-CCK. As Commander of
the USA-CCK, defendant RICHARD J. MORAN supervised a staff of
approximately 140 and was responsible for oversight, approval, and
execution of more than 17,000 contracts with an annual valuation of
more than $310 million.
3. As Commander of the USA-CCK, defendant RICHARD J. MORAN
was bound to conduct government business in a manner above
reproach, and except as authorized by statute or regulation, with
complete impartiality and with preferential treatment for none.
4. Defendant RICHARD J. MORAN’s specific responsibilities as
Commander of the USA-CCK included established objectives of
developing a genuine competitive contracting environment and saving
the United States Forces Korea in excess of $135 million from
estimated costs of procurement by end of Fiscal Year 2002.
5. Defendant GINA C. MORAN was married to defendant RICHARD
J. MORAN. Defendant GINA C. MORAN was not employed by the USA-CCK.
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COUNT ONE
[18 U.S.C. § 371]
A. BACKGROUND
Aulson and Sky Contracts
6. Aulson and Sky Construction Company, Ltd., ("A&S") was
based in the Republic of Korea. Unindicted co-conspirator Kyu Chun
Chong was President of A&S.
7. In or about March 2001, A&S submitted a bid for a
contract to improve military family housing at the Osan Air Base
in the Republic of Korea ("Military Family Housing Contract"). The
USA-CCK specified that the contract should be awarded to the lowest
priced, technically acceptable offer that satisfied the terms and
conditions of the solicitation. The government estimated the value
of the contract as approximately $1.9 million.
8. Of the 16 companies that submitted bids for the Military
Family Housing Contract, A&S was ranked 11th for its proposed
price, and later ranked second among those initially deemed
technically acceptable by the USA-CCK. After the USA-CCK conducted
a further assessment, the USA-CCK awarded the Military Family
Housing Contract to A&S.
9. In or about May 2001, A&S submitted a bid for a contract
to upgrade and renovate barracks at Camp Carroll in the Republic of
Korea ("Camp Carroll Contract"). The USA-CCK specified that the
contract should be awarded to the lowest priced, technically
acceptable offer that satisfied the terms and conditions of the
solicitation. The government estimated the value of the Camp
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Carroll Contract as approximately $6.5 million.
10. Of the 17 companies that submitted bids for the Camp
Carroll Contract, A&S was ranked 15th for its proposed price, and
later ranked second among those deemed technically acceptable by
the USA-CCK. After the USA-CCK conducted a further assessment, the
USA-CCK awarded the Camp Carroll Contract to A&S.
11. In or about August 2001, A&S submitted a bid for a
contract for a comprehensive barracks upgrade and renovation in the
Republic of Korea ("Area 1 Contract"). The USA-CCK specified that
the contract should be awarded to the lowest priced, technically
acceptable offer that satisfied the terms and conditions of the
solicitation. The government estimated the value of the Area 1
Contract as approximately $16.3 million.
12. Of the 10 companies that submitted bids for the Area 1
Contract, A&S was ranked ninth for its proposed price, and later
ranked third among those deemed technically acceptable by the USA-
CCK. After the USA-CCK conducted a further assessment, the USA-CCK
awarded the Area 1 Contract to A&S.
IBS Industries Company Contract
13. IBS Industries Company, Ltd., ("IBS") was a company based
in the Republic of Korea. Unindicted co-conspirator Woong-Seo Koo
was the Chief Executive Officer and Chairman of IBS.
14. In or about September 2001, IBS submitted a bid for a
contract for uniformed civilian security guards throughout the
Republic of Korea ("Security Guard Contract"). IBS employed
defendant JOSEPH K. HUR as a consultant for purposes of obtaining
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the Security Guard Contract.
15. The USA-CCK specified that the contract should be awarded
to the offeror that provided best value to the government, and that
satisfied the terms and conditions of the solicitation. The
government estimated the value of the Security Guard Contract as
approximately $112 million.
16. Of the 11 companies that submitted bids for the Security
Guard Contract, IBS was ranked eighth for its proposed price, and
later ranked second among those deemed technically acceptable by
the USA-CCK. The USA-CCK then awarded a portion of the Security
Guard Contract to IBS.
B. OBJECT OF THE CONSPIRACY
17. Beginning in or about February 2001 and continuing to in
or about January 16, 2002, in the Republic of Korea, defendants
RICHARD J. MORAN, GINA C. MORAN, JOSEPH K. HUR and others known and
unknown to the grand jury willfully conspired and agreed with each
other to commit an offense against the United States, namely, to
solicit, offer, receive and agree to receive bribes in violation of
Title 18 United States Code, Section 201.
18. The plan and purpose of this conspiracy was for defendant
RICHARD J. MORAN to receive bribes from Korean companies either
personally or through defendants GINA C. MORAN and JOSEPH K. HUR in
exchange for his efforts to secure the award of United States
military contracts to those Korean companies.
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C. MEANS BY WHICH THE OBJECT OF THE CONSPIRACY WAS TO BE
ACCOMPLISHED
The objects of the conspiracy were to be accomplished in
substance as follows:
19. Defendant RICHARD J. MORAN would agree to cause the USA-
CCK to award United States military contracts to Korean companies
in exchange for negotiated bribes.
20. Defendants GINA C. MORAN and JOSEPH K. HUR would specify
the form of bribery payment and would collect the bribery payments
on behalf of co-defendant RICHARD J. MORAN.
D. OVERT ACTS
21. In furtherance of the conspiracy and to accomplish the
object of the conspiracy, defendants RICHARD J. MORAN, GINA C.
MORAN and JOSEPH K. HUR committed various overt acts in the
Republic of Korea, including but not limited to the following:
a. In or about February 2001, in the Republic of Korea,
defendant RICHARD C. MORAN secured an agreement from A&S through an
unindicted co-conspirator to pay 150 million Korean Won in exchange
for the award of the Military Family Housing Contract.
b. In or about February 2001, in the Republic of Korea,
defendant RICHARD J. MORAN used an unindicted co-conspirator to
provide details of the confidential Independent Government Cost
Estimate to A&S to assist A&S in its bid for the Military Family
Housing Contract.
c. In or about May 2001, in the Republic of Korea, Kyu
Chun Chong of A&S paid 50 million Korean Won to an unindicted co-
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conspirator recruited by defendant RICHARD J. MORAN.
d. In or about May, 2001, in the Republic of Korea,
defendant GINA C. MORAN met with Kyu Chun Chong of A&S and agreed
to an additional payment of $50,000 in exchange for the award of
the Military Family Housing Contract to A&S.
e. In or about September 2001, in the Republic of
Korea, after the award of the Military Family Housing Contract to
A&S, defendant GINA C. MORAN instructed Kyu Chun Chong that the
$50,000 payment must be in the form of United States currency in
$100 denominations.
f. In or about September 2001, at the Yongsan Army base
in the Republic of Korea, defendant GINA C. MORAN collected from
Kyu Chun Chong $50,000 in $100 denominations in exchange for the
award of the Military Family Housing Contract to A&S.
g. In or about May 2001, prior to any bids being
submitted for the award of the Camp Carroll Contract, defendant
RICHARD J. MORAN took possession of the Camp Carroll Contract
files, which contained the confidential Independent Government Cost
Estimate.
h. In or about May 2001, defendant RICHARD J. MORAN
provided defendant GINA C. MORAN with details from the confidential
Independent Government Cost Estimate and a suggested bid amount for
the Camp Carroll Contract.
i. In or about May 2001, in a meeting at the Yongsan
Army base in the Republic of Korea, defendant GINA C. MORAN met
with Kyu Chun Chong and agreed to a payment of $200,000 in exchange
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for the award of the Camp Carroll Contract to A&S.
j. In or about May 2001, in a meeting at the Yongsan
Army base in the Republic of Korea, defendant GINA C. MORAN
provided Kyu Chun Chong with details from the confidential
Independent Government Cost Estimate and a suggested bid amount for
the Camp Carroll Contract.
k. In or about June 2001, defendant RICHARD J. MORAN
reviewed information regarding the two lowest bids received on the
Camp Carroll Contract, in which A&S was the second lowest bidder.
l. In or about June 2001, defendant RICHARD J. MORAN
advised Kyu Chun Chong of A&S that it was not the low bidder on the
Camp Carroll Contract, and that A&S would have to submit a Best and
Final Offer.
m. In or about July 2001, after the award of the Camp
Carroll Contract to A&S, defendant GINA C. MORAN instructed Kyu
Chun Chong that the $200,000 payment must be in the form of United
States currency in $100 bill denominations.
n. In or about July and August 2001, defendant GINA C.
MORAN collected installment payments from Kyu Chun Chong totaling
$200,000 in $100 denominations in exchange for the award of the
Camp Carroll Contract to A&S.
o. In or about August 2001, defendant RICHARD J. MORAN
provided defendant GINA C. MORAN with details from the confidential
Independent Government Cost Estimate for the Area I Contract.
p. In or about August 2001, in a meeting at the Yongsan
Army base, defendant GINA C. MORAN met with Kyu Chun Chong and
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agreed to a payment of $500,000 in exchange for the award of the
Area I Contract to A&S.
q. In or about August 2001, in a meeting at the Yongsan
Army base, defendant GINA C. MORAN provided Kyu Chun Chong with
details from the confidential Independent Government Cost Estimate
for the Area I Contract.
r. In or about August 2001, after all companies
interested in the award of the Area I Contract had submitted their
bids to the USA-CCK but before the award of the contract, defendant
RICHARD J. MORAN took possession of the price negotiation
memorandum, which reflected that the Area I Contract should be
awarded to a company other than A&S.
s. In or about August 2001, defendant RICHARD J. MORAN
directed his subordinate to collect the files for the Area I
Contract, including the bids submitted by all contractors, in order
to perform a different analysis of the cost and pricing data
submitted by the technically acceptable contractors.
t. In or about September 2001, defendant RICHARD J.
MORAN advised employees of the USA-CCK that the contractors who had
submitted bids lower than A&S were not appropriate for the award of
the contract, leaving A&S as the lowest priced, technically
acceptable contractor for the Area I Contract.
u. In or about November and December 2001, at the
Yongsan Army base, defendant GINA C. MORAN collected installment
payments from Kyu Chun Chong totaling $150,000 in $100
denominations in exchange for the award of the Area I Contract to
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A&S.
v. In or about August 2001, defendants RICHARD J. MORAN
and JOSEPH K. HUR met to discuss the award of the Security Guard
Contract.
w. In or about August 2001, defendant RICHARD J. MORAN
provided defendant JOSEPH K. HUR with the name of a company that
could bid on the Security Guard Contract, namely IBS.
x. In or about August 2001, defendant JOSEPH K. HUR met
with representatives of IBS to discuss a possible bid on the
Security Guard Contract.
y. Later in or about August 2001, defendants RICHARD J.
MORAN and JOSEPH K. HUR decided that HUR could serve as a
"consultant" to IBS to assist it in the award of the contract in
exchange for payment to MORAN and HUR.
z. In or about August 2001, defendant RICHARD J. MORAN
assured defendant JOSEPH K. HUR that MORAN would assist HUR in
securing the award of the Security Guard Contract for IBS.
aa. In or about August 2001, defendants RICHARD J. MORAN
and JOSEPH K. HUR reviewed and approved the terms of the
"consulting" agreement between IBS and HUR.
bb. In or about August 2001, defendant RICHARD J. MORAN
advised defendant JOSEPH K. HUR not to divulge his involvement with
HUR on the Security Guard Contract.
cc. In or about October 2001, defendant RICHARD J. MORAN
advised defendant JOSEPH K. HUR that IBS would receive a portion of
the Security Guard Contract.
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dd. In or about October 2001, after IBS received a
portion of the Security Guard Contract, Woong-Seo Koo of IBS
provided $20,000 in $100 denominations, along with Korean Won bank
checks, to defendant JOSEPH K. HUR.
ee. In or about October 2001, defendant JOSEPH K. HUR
provided defendant RICHARD J. MORAN with half of the money and bank
checks paid to HUR by IBS.
ff. In or about December 2001, defendant RICHARD J.
MORAN advised defendant JOSEPH K. HUR that more money should be
paid by IBS for the award of the Security Guard Contract.
gg. In or about December 2001, defendant JOSEPH K. HUR
contacted Woong-Seo Koo of IBS, and demanded an additional payment
for the award of the Security Guard Contract.
hh. In or about December 18, 2001, defendant JOSEPH K.
HUR received additional Korean Won bank checks from Woong-Seo Koo
of IBS.
ii. In or about December 2001, defendant JOSEPH K. HUR
provided defendant RICHARD J. MORAN with half of the bank checks
paid to HUR by IBS.
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COUNT TWO
[18 U.S.C. §§ 201(b), 2(a)]
22. Paragraphs 1 through 18 are re-alleged and incorporated
by reference as though set forth in full.
23. On or about May 2001, in the Republic of Korea, defendant
RICHARD J. MORAN, a Colonel in the United States Army and Commander
of the USA-CCK, corruptly sought, received and agreed to receive
approximately $50,000 in return for being influenced in the
performance of any official act, and being induced to do any act in
violation of his official duty, in conjunction with the award of
the Military Family Housing Contract by the USA-CCK.
At the above time and place, defendant GINA C. MORAN aided,
abetted, counseled, induced and procured the commission of the
offense alleged above.
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COUNT THREE
[18 U.S.C. §§ 201(b), 2(a)]
24. Paragraphs 1 through 18 are re-alleged and incorporated
by reference as though set forth in full.
25. In or about May 2001, in the Republic of Korea, defendant
RICHARD J. MORAN, a Colonel in the United States Army and Commander
of the USA-CCK, corruptly sought, received and agreed to receive
approximately $200,000 in return for being influenced in the
performance of any official act, and being induced to do any act in
violation of his official duty, in conjunction with the award of
the Camp Carroll Contract by the USA-CCK.
At the above time and place, defendant GINA C. MORAN aided,
abetted, counseled, induced and procured the commission of the
offense alleged above.
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COUNT FOUR
[18 U.S.C. §§ 201(b), 2(a)]
26. Paragraphs 1 through 18 are re-alleged and incorporated
by reference as though set forth in full.
27. In or about August 2001, in the Republic of Korea,
defendant RICHARD J. MORAN, a Colonel in the United States Army and
Commander of the USA-CCK, corruptly sought, received and agreed to
receive approximately $500,000 in return for being influenced in
the performance of any official act, and being induced to do any
act in violation of his official duty, in conjunction with the
award of the Area 1 Contract by the USA-CCK.
At the above time and place, defendant GINA C. MORAN aided,
abetted, counseled, induced and procured the commission of the
offense alleged above.
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COUNT FIVE
[18 U.S.C. §§ 201(b), 2(a)]
28. Paragraphs 1 through 18 are re-alleged and incorporated
by reference as though set forth in full.
29. In or about August 2001, in the Republic of Korea,
defendant RICHARD J. MORAN, a Colonel in the United States Army and
Commander of the USA-CCK, corruptly sought, received and agreed to
receive money in return for being influenced in the performance of
any official act, and being induced to do any act in violation of
his official duty, in conjunction with the award of the Security
Guard Contract by the USA-CCK.
At the above time and place, defendant JOSEPH K. HUR aided,
abetted, counseled, induced and procured the commission of the
offense alleged above.
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COUNT SIX
[18 U.S.C. § 1956(h)]
A. INTRODUCTION
30. Paragraphs 1 through 18 are re-alleged and incorporated
by reference as though set forth in full.
B. OBJECT OF THE CONSPIRACY
31. From in or about April 2001 and continuing to in or about
February 2002, in the Republic of Korea and elsewhere, defendants
RICHARD C. MORAN and GINA C. MORAN and others known and unknown to
the Grand Jury, knowingly and willfully conspired and agreed with
each other to conduct and aid and abet the conducting of financial
transactions affecting foreign and interstate commerce, which
involved the proceeds of bribery, knowing that the transactions
were designed in whole and in part to conceal and disguise the
nature, location, source, ownership, and control of the proceeds,
and knowing that the property involved in the financial transaction
represented the proceeds of some form of unlawful activity, in
violation of Title 18, United States Code, Sections
1956(a)(1)(B)(i) and 2(a).
B. MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE
ACCOMPLISHED
The objects of the conspiracy were to be accomplished in
substance as follows:
32. Defendant GINA C. MORAN would collect bribery payments on
behalf of defendant RICHARD C. MORAN.
33. Defendants RICHARD C. MORAN and GINA C. MORAN would delay
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deposit of the bribery proceeds into bank accounts by storing the
bribery proceeds at their residence.
34. Defendants RICHARD C. MORAN and GINA C. MORAN would then
transport the proceeds from the Republic of Korea to the United
States, purchase cashier’s checks and deposit cashier’s checks and
currency into different bank accounts in the United States.
C. OVERT ACTS
35. In furtherance of the conspiracy and to accomplish the
objects of the conspiracy, defendants RICHARD C. MORAN and GINA C.
MORAN committed various overt acts in the Republic of Korea and
elsewhere, including but not limited to the following:
a. In or about April 30, 2001, in the Republic of
Korea, defendants RICHARD C. MORAN and GINA C. MORAN collected
bribery proceeds of approximately $40,000 from an associate who had
received that money from Kyu Chun Chong of A&S.
b. On or about June 9, 2001, defendants RICHARD C.
MORAN and GINA C. MORAN transported $40,000 in cash bribery
proceeds from the Republic of Korea to the United States of
America.
c. On or about June 17, 2001, defendant RICHARD J.
MORAN deposited $11,000 in cash bribery proceeds into a joint
savings account at a Bank of America branch in Virginia.
d. On or about June 17, 2001, defendant RICHARD J.
MORAN deposited $5,000 in cash bribery proceeds into a joint
checking account at a Bank of America branch in Virginia.
e. On or about June 17, 2001, in Virginia, defendants
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RICHARD C. MORAN and GINA C. MORAN purchased Bank of America
cashier’s checks in the amounts of $20,000 and $4,000 with cash
bribery proceeds.
f. On or about June 18, 2001, in Virginia, defendants
RICHARD C. MORAN and GINA C. MORAN deposited the Bank of America
cashier’s checks totaling $24,000 into three separate Legg Mason
investment accounts.
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COUNTS SEVEN THROUGH EIGHT
[18 U.S.C. §§ 1957; 2(a)]
36. On or about the dates set forth below, in the Republic of
Korea, knowing that the funds involved in the transactions
represented the proceeds of some form of unlawful activity,
defendants RICHARD J. MORAN and GINA C. MORAN did knowingly and
willfully conduct, aid, abet, counsel, induce, procure and cause to
be conducted monetary transactions involving criminally derived
property of a value of greater than $10,000, property that was in
fact derived from bribery:
COUNT DATE AMOUNT TRANSACTION
7 1/31/02 $50,960.30 Wire transfer of funds froma Legg Mason account in Virginia to Korea Exchange Bank in the Republic of Korea
8 2/14/02 $16,500.00 Cash withdrawal from Community Bank in the Republic of Korea
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COUNT NINE
[18 U.S.C. § 1512(b)(3)]
A. INTRODUCTION
37. Between in or about May 2001 and December 2001, defendant
GINA C. MORAN obtained the proceeds of bribes, totaling
approximately $400,000 in cash, as alleged above in paragraphs 1
through 18, which are incorporated herein by reference.
38. Between in or about May 2001 and December 2001, defendant
GINA C. MORAN secreted the $400,000 in bribery proceeds, as well as
an additional approximate $300,000 in cash, in the living room sofa
in the residence of defendants RICHARD J. MORAN and GINA C. MORAN
on the Yongsan Army base in Seoul, in the Republic of Korea.
39. On or about January 16, 2002, criminal investigators from
the Army executed a search warrant at the residence of defendants
RICHARD J. MORAN and GINA C. MORAN on the Yongsan Army base in
Seoul, in the Republic of Korea.
B. OBSTRUCTION OF JUSTICE
40. On or about January 16, 2002, in the Republic of Korea,
defendant GINA C. MORAN did knowingly engage in misleading conduct
toward agents of the Army Criminal Investigative Division with the
intent to hinder, delay, and prevent the communication to a law
enforcement officer of information relating to the commission of
bribery; namely, by making repeated trips from the living room to
her bedroom for the stated reason of illness while moving
approximately $700,000 in United States currency from the living
room sofa to the bedroom after Army criminal investigators had
searched the bedroom.
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COUNT TEN
[18 U.S.C. § 371]
A. INTRODUCTION
41. As Commander of the USA-CCK, defendant RICHARD J. MORAN
was responsible for oversight, approval, and execution of contracts
that included contract DAJB03-01-C-0274 for computer services at
the USA-CCK ("Computer Services Contract").
42. Defendant RONALD A. PARRISH was the Chief of the Contract
Support Division at the USA-CCK, and had access to the bids
received on the Computer Services Contract.
43. Defendant RICHARD L. CARLISLE, residing in the Republic
of Korea, submitted a bid on the Computer Services Contract under
the name of Carlisle Consulting Company.
B. OBJECTS OF THE CONSPIRACY
44. Beginning in or about July 2001 and continuing to on or
about September 25, 2001, in the Republic of Korea, defendants
RICHARD J. MORAN, RONALD A. PARRISH, RICHARD L. CARLISLE, and
others known and unknown to the grand jury willfully conspired and
agreed with each other to commit an offense against the United
States, namely, to disclose and obtain contractor bid or proposal
information prior to the award of the contract, in violation of
Title 41 United States Code, Section 423.
45. The plan and purpose of this conspiracy was for
defendants RICHARD J. MORAN and RONALD A. PARRISH to provide a
competitive advantage to defendant RICHARD L. CARLISLE by
disclosing to defendant RICHARD L. CARLISLE a competitor’s bid or
proposal information for the Computer Services Contract.
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C. MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WAS TO BE
ACCOMPLISHED
The objects of the conspiracy were to be accomplished in
substance as follows:
46. Defendant RICHARD J. MORAN would solicit bid or proposal
information from a competing company seeking the Computer Services
Contract.
47. Defendant RICHARD J. MORAN would direct defendant RONALD
A. PARRISH to disclose the bid or proposal information of the
competing company to defendant RICHARD L. CARLISLE.
48. Defendant RICHARD L. CARLISLE would receive the bid or
proposal information of the competing company and use it in the
preparation of his bid for the Computer Services Contract.
D. OVERT ACTS
49. In furtherance of the conspiracy and to accomplish the
object of the conspiracy, defendants RICHARD J. MORAN, RONALD A.
PARRISH and RICHARD L. CARLISLE committed various overt acts in the
Republic of Korea, including but not limited to the following:
a. In or about July 2001, in the Republic of Korea,
defendant RICHARD J. MORAN solicited American Management Systems,
Inc., the incumbent contractor, to bid on the next year's Computer
Services Contract.
b. In or about August 2001, defendant RICHARD J. MORAN
directed defendant RONALD A. PARRISH to disclose the bid and
proposal information received from American Management Systems,
Inc. to defendant RICHARD L. CARLISLE.
c. On or about August 21, 2001, defendant RONALD A.
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PARRISH sent an electronic message to defendant RICHARD L.
CARLISLE, to which defendant PARRISH attached the bid and proposal
information received from American Management Systems, Inc.
d. On or about August 21, 2001, defendant RICHARD L.
CARLISLE received the bid and proposal information of American
Management Systems, Inc.
e. On or about September 12, 2001, defendant RICHARD L.
CARLISLE submitted his bid for the Computer Services Contract.
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COUNT ELEVEN
[41 U.S.C. § 423(a); 18 U.S.C. § 2(a)]
A. INTRODUCTION
50. Paragraphs 41 through 48 of this Indictment are re-
alleged and incorporated by reference as though set forth in full.
B. PROCUREMENT INTEGRITY ACT VIOLATION
51. On or about August 21, 2001, in the Republic of Korea,
defendants RICHARD J. MORAN and RONALD A. PARRISH, officials of the
United States, assisting with the award of a Federal agency
procurement, aiding and abetting each other, knowingly disclosed
contractor bid or proposal information prior to the award of the
contract, namely, the bid and proposal information of American
Management Systems, Inc.
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52. At the above time and place, defendant RICHARD L.
CARLISLE aided, abetted, counseled, induced and procured the
commission of the offense alleged above.
A TRUE BILL
__________________________Foreperson
DEBRA W. YANGUnited States Attorney
JOHN S. GORDONAssistant United States AttorneyChief, Criminal Division
JOHN C. HUESTONAssistant United States AttorneyChief, Santa Ana Branch Office
