Steve Ellis - Ted Klein - Edward MacKenzie - 02-27-2015.pdf

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1 The Massachusetts Association of the New Jerusalem(Swedenborgian) and George Chapin.

2 Thomas Kennedy; Boston Society of the New Jerusalem,Incorporated (Swedenborgian); and Bostonview Corporation.

NOTICE: All slip opinions and orders are subject to formalrevision and are superseded by the advance sheets and boundvolumes of the Official Reports. If you find a typographicalerror or other formal error, please notify the Reporter ofDecisions, Supreme Judicial Court, John Adams Courthouse,Pemberton Square, Suite 2500, Boston, MA 02108-1750; (617) 557-

1030; [email protected]

SJC-09856

THE GENERAL CONVENTION OF THE NEW JERUSALEM IN THE UNITED STATESOF AMERICA, INC., & others1 vs. EDWARD MacKENZIE & others.2

Suffolk. September 5, 2007. - October 15, 2007.

Present: Marshall, C.J., Greaney, Ireland, Spina, Cowin, &

Cordy, JJ.

Practice, Civil, Complaint, Motion to dismiss. Religion.Jurisdiction, Ecclesiastical controversy. Contract,Construction of contract, Church. Conversion. Words,"Cease to exist."

Civil action commenced in the Superior Court Department onAugust 4, 2004.

Motions to dismiss were heard by Patrick F. Brady, J., andentry of judgment was ordered by Catherine A. White, J.

After review by the Appeals Court, the Supreme JudicialCourt granted leave to obtain further appellate review.

Howard M. Cooper (Julie E. Green with him) for thedefendants.

Lawrence R. Kulig (Damon P. Hart with him) for theplaintiffs.

COWIN, J. The defendant Boston Society of the New



2

3 The parenthetical "Swedenborgian" is part of the officialname of the defendant Boston church as well as the plaintiffMassachusetts Association of the New Jerusalem.

Jerusalem, Incorporated (Swedenborgian)3 (the church or the

Boston church), is a Swedenborgian church that disaffiliated from

(withdrew from membership in) the plaintiff General Convention of

the New Jerusalem in the United States of America, Inc. (the

General Convention or the national body), a national denomination

of congregational Swedenborgian churches. The national body

commenced a civil action in the Superior Court, seeking, among

other things, a judgment declaring that, under the Boston

church's bylaws, this disaffiliation triggered a transfer of the

Boston church's assets to the national body. In a related claim,

the national body asserted that, because the disaffiliation

caused ownership of the Boston church's assets to transfer to the

national body, the retention of these assets by individual

defendants Edward MacKenzie and Thomas Kennedy created a

conversion. A judge in the Superior Court granted the

defendants' motions to dismiss. The Appeals Court reversed the

judgment with regard to these issues, while affirming the rest of

the judgment. The Gen. Convention at the New Jerusalem in the

U.S., Inc. v. MacKenzie, 66 Mass. App. Ct. 836, 844 (2006). We

granted further appellate review limited to these issues, and now

affirm the dismissal of these counts for failure to state a claim

upon which relief can be granted.

1. Facts. We summarize the relevant facts as alleged in



3

the amended complaint. Since its founding in 1818, the church

has been affiliated with the General Convention. Under the

leadership of MacKenzie and Kennedy, however, the church broke

away from the General Convention in 2003. Prior to its

disaffiliation, the church's bylaws contained numerous references

to the General Convention. The provision at the heart of this

litigation is entitled "Dissolution" and states:

"In the event that the religious body known as theBoston Society of the New Jerusalem, Inc. shall cease toexist, all funds and holdings shall be transferred to the

General Convention of the New Jerusalem in the United Statesof America.

"These assets shall be held in escrow for theestablishment of another General Convention of the NewJerusalem (Swedenborgian) Church within the City of Boston,Massachusetts. After a period of twenty (20) years, shouldno such Church exist, the capital and income therefrom shallrevert to the General Convention of the New Jerusalem(Swedenborgian) with any restrictions of uses which may havebeen voted by the Society members at the time of thedissolution."

Since disaffiliation, the church has continued to function

under the corporate name of the Boston Society of the New

Jerusalem, Inc. (Swedenborgian). It retains the same pastor and

carries on many of the same church and charitable services as it

had prior to disaffiliation.

The plaintiffs filed an eleven-count complaint in the

Superior Court. Count I sought a declaration that, by virtue of

the Boston church's organizational bylaws, at the time of its

disaffiliation from the General Convention, all of the Boston

church's assets reverted to the General Convention to be held in

trust for the establishment of another affiliated church. Count



4

II alleged that the individual defendants wrongfully converted

the assets of the General Convention to their own use. A judge

in Superior Court allowed the defendants' motions to dismiss all

of the plaintiffs' claims. See Mass. R. Civ. P. 12 (b) (6), 365

Mass. 754 (1974). With respect to count I, the Superior Court

judge reasoned that the language of the dissolution bylaw was

unambiguous and did not apply to a disaffiliation from the

General Convention after which the church continued to exist.

The Superior Court judge also dismissed the plaintiffs' claims

for mismanagement and misappropriation of assets for lack of

standing, explaining that "[s]uch authority rests exclusively

with the attorney general."

The Appeals Court affirmed the judgments of dismissal except

in regard to counts I and II, ruling that these counts should

proceed. The Gen. Convention of the New Jerusalem in the U.S.,

Inc. v. MacKenzie, supra. The Appeals Court held that the

dissolution bylaw was ambiguous because "the term 'cease to

exist' is 'susceptible of more than one meaning and reasonably

intelligent persons would differ as to which meaning is the

proper one.'" Id. at 842, quoting County of Barnstable v.

American Fin. Corp., 51 Mass. App. Ct. 213, 215 (2001). Thus,

the bylaw could apply to both disaffiliation and dissolution.

The Appeals Court interpreted count II's conversion claim as

"premised on the proposition that MacKenzie and Kennedy

wrongfully converted assets of the General Convention for their

own use," id. at 843 n.10, and thus permitted that count to



5

4 As the Appeals Court concluded, the First Amendment to theUnited States Constitution does not prohibit a civil court fromexercising jurisdiction over property disputes involving a churchso long as the court does not intrude upon issues of churchdoctrine, polity, discipline, and internal operation. See TheGen. Convention of the New Jerusalem in the U.S., Inc. v.MacKenzie, 66 Mass. App. Ct. 836, 839-840 (2006), citing Callahanv. First Congregational Church, 441 Mass. 699, 708 (2004), andJones v. Wolf, 443 U.S. 595, 602 (1979).

proceed as well.

We conclude that the dissolution bylaw was not triggered by

the disaffiliation because the plain text of the bylaw clearly

contemplated only dissolution of the entity itself. Since the

church remains the rightful owner of its assets, the plaintiffs'

conversion claim also fails.

2. Dissolution bylaw. In reviewing a motion to dismiss, we

accept as true all factual allegations in the complaint, and draw

all reasonable inferences in favor of the plaintiffs. Nader v.

Citron, 372 Mass. 96, 98 (1977). The complaint should not be

dismissed for failure to state a claim unless it appears beyond a

doubt that the plaintiffs can prove no set of facts which entitle

them to relief. Id.

The bylaws of a church corporation form a contract between

the church and its members, and are interpreted according to

principles of contract law.4 See Mitchell v. Albanian Orthodox

Diocese in Am., Inc., 355 Mass. 278, 282 (1969); Kubilius v.

Hawes Unitarian Congregational Church, 322 Mass. 638, 644 (1948).

The words of a contract must be considered in the context of the

entire contract rather than in isolation. See Starr v. Fordham,



6

420 Mass. 178, 190 (1995); Charles I. Hosmer, Inc. v.

Commonwealth, 302 Mass. 495, 501-502 (1939). When the words of a

contract are clear, they must be construed in their usual and

ordinary sense, Ober v. National Cas. Co., 318 Mass. 27, 30

(1945), and we do not admit parol evidence to create an ambiguity

when the plain language is unambiguous, Panikowski v. Giroux, 272

Mass. 580, 583 (1930). In Robert Indus., Inc. v. Spence, 362

Mass. 751, 753-754 (1973), we explained that extrinsic evidence

may be admitted when a contract is ambiguous on its face or as

applied to the subject matter. The initial ambiguity must exist,

however. Furthermore, extrinsic evidence cannot be used to

contradict or change the written terms, but only to remove or to

explain the existing uncertainty or ambiguity. Id.

With these legal principles in mind, we turn to the facts of

this case. The General Convention argues that the dissolution

bylaw is ambiguous, and could apply to a disaffiliation of the

church from the General Convention in addition to a dissolution

of the church. The thrust of the argument is that the words "the

religious body" could refer not only to "the Boston Society of

the New Jerusalem, Inc.," as explicitly stated in the text, but

also to "a religious body affiliated with the General

Convention." Although the latter phrase is not found in the

plain text of the dissolution bylaw, the General Convention

argues that it is a possible interpretation. Upon

disaffiliation, the "religious body affiliated with the General

Convention" would thus "cease to exist." Another way to put the



7

5 General Laws c. 180, § 11A, provides as follows:

"A charitable corporation constituting a public charity. . . which desires to close its affairs may, by vote of amajority of its board of directors, authorize a petition forits dissolution to be filed in the supreme judicial courtsetting forth in substance the grounds of the applicationfor dissolution and requesting the court to authorize theadministration of its funds for such similar publiccharitable purposes as the court may determine. Theprovisions of this section shall constitute the sole methodfor the voluntary dissolution of any such charitableorganization."

argument is that "cease to exist" is ambiguous, and could mean

both "to dissolve" and "to disaffiliate." See The Gen.

Convention of the New Jerusalem in the U.S., Inc. v. MacKenzie,

supra at 842.

We do not locate an ambiguity in the language of the

dissolution bylaw, and hold that it is triggered only upon

dissolution, and not by disaffiliation. Massachusetts mandates

that charities follow certain statutory procedures for

dissolution, see G. L. c. 180, § 11A,5 and the church has taken

none of these steps. More importantly, it is undisputed that the

church continues to exist, and that it engages in religious and

charitable activities, much as it had done before disaffiliation.

Turning to the plain text of the bylaw, it is entitled

"Dissolution," and disaffiliation is mentioned nowhere in the

text. The text concerns only the "ceasing to exist" of "the

religious body known as the Boston Society of the New Jerusalem,

Inc." Our interpretation is supported by the final sentence of

the bylaw, which provides that the use of reverted church assets



8

will be in accordance with "any restrictions of uses which may

have been voted by the [church] members at the time of

dissolution." To read disaffiliation into this text is to strain

the plain words more than contract law permits.

Plaintiffs argue that language stating that assets "shall be

held in escrow for the establishment of another General

Convention of the New Jerusalem (Swedenborgian) Church" renders

the term "religious body" ambiguous. We discern no ambiguity.

This language is consistent with dissolution. It may indicate

the close relationship between the church and the General

Convention at the time the church bylaws were drafted, but that

fact does not create ambiguity in an otherwise clear text.

Plaintiffs also argue that, if interpreted in the context of

certain other articles of the bylaws, the dissolution bylaw could

reasonably refer to disaffiliation. We disagree. Article III

refers to affiliation with the General Convention since 1818 and

the church's delegates' right to participate and vote at the

General Convention's meetings. Article IV refers to transfers of

membership to the church from other General Convention affiliated

churches. Article VI provides for the election of a new pastor

for the church, and requires that the new pastor be in good

standing with the General Convention. Similar to the dissolution

bylaw, these provisions also indicate the cooperative

relationship between the church and the General Convention at the

time of the drafting of the bylaws. They do not, however, create

an ambiguity that "ceasing to exist" was intended to mean



9

"disaffiliation."

Other States have taken a position in accord with the one we

take today. For example, in Christensen v. Roumfort, 20 Ohio

App. 3d 107, 108 (1984), the Court of Appeals of Ohio considered

a provision stating that the United Presbyterian Church in the

United States of America (UPCUSA) would gain control of a local

church's property "[w]henever hereafter a particular church is

formally dissolved by the presbytery, or has become extinct by

reason of the dispersal of its members, the abandonment of its

work, or other cause . . . ." The court held that the church was

not extinct even though it had disaffiliated from UPCUSA. Id. at

110. In First Presbyterian Church v. United Presbyterian Church

in the United States, 62 N.Y.2d 110, 123, cert. denied, 469 U.S.

1037 (1984), the Court of Appeals of New York considered a UPCUSA

provision stating that whenever a local church is dissolved, its

property shall revert to UPCUSA. The court held that the local

church's disaffiliation from UPCUSA was not a dissolution or

extinction that would trigger this provision. See id. The

Supreme Court of Missouri reached the same conclusion as the

courts in Ohio and New York on nearly identical facts in

Presbytery of Elijah Parish Lovejoy v. Jaeggi, 682 S.W.2d 465,

474 (Mo. 1984). Those jurisdictions that have awarded property

from a local church to the parent church upon disaffiliation

generally have done so on the basis of different assumptions as



10

6 See, e.g., Central Coast Baptist Ass'n v. First BaptistChurch, 154 Cal. App. 4th 586, 592 (2007) (holding thatdisaffiliated church had de facto dissolved when last vote of itsfull membership was to dissolve and to transfer assets to motherchurch); Wisconsin Conference Bd. of Trustees of the UnitedMethodist Church, Inc. v. Culver, 243 Wis. 2d 394, 407-409 (2001)(holding that disaffiliated church had dissolved within meaningof State law when statute provided assets shall revert toMethodist denomination "[w]henever any local Methodist church orsociety shall become defunct or dissolved").

7 We thus do not consider allegations in the amendedcomplaint and in the affidavit of John Perry regardingcircumstances surrounding the drafting of the dissolution bylaw.

to the facts.6 To the extent that the facts are not

distinguishable, we nevertheless decline to follow the reasoning

of these other courts.

Since the plain language of the dissolution bylaw is

unambiguous, we do not consider extrinsic evidence such as

allegations of what was intended when the dissolution bylaw was

drafted.7 Plaintiffs argue that we are required, in reviewing

the motion to dismiss, to accept the General Convention's reading

of the dissolution bylaw in favor of the General Convention, as a

true factual allegation or reasonable inference. But the proper

interpretation of the bylaw is a matter of law, Berkowitz v.

President & Fellows of Harvard College, 58 Mass. App. Ct. 262,

270 (2003), and legal conclusions cast in the form of factual

allegation are not taken as true on a motion to dismiss, Schaer

v. Brandeis Univ., 432 Mass. 474, 477-478 (2000).

3. Conversion. The plaintiffs' claim against the

individual defendants MacKenzie and Kennedy for conversion also

fails. Count II of the amended complaint alleged that (1) the



11

assets of the church, as a result of the disaffiliation, were the

property of the General Convention; (2) the individual defendants

knew or should have known that they had no right to this

property; and (3) the individual defendants, nonetheless,

exercised acts of ownership and control over these assets for

their own personal gain.

The defendants' primary argument is that plaintiffs have no

standing to bring this claim, because the Attorney General has

exclusive jurisdiction, with narrow exceptions, over management

of charitable assets. Weaver v. Wood, 425 Mass. 270, 275-277

(1997). We need not address the issue of standing here. The

conversion claim is premised on the fact that the General

Convention is the rightful owner of the church's assets. Since

we have rejected the General Convention's claim of ownership, the

conversion claim fails on substantive grounds.

Accordingly, we affirm the judgment of the Superior Court as

to counts I and II.

Judgment affirmed.



UNITED STATES DISTRICT COURT

DISTRICT

OF MASSACHUSETTS

UNITED STATES

OF AMERICA

VIOLATIONS:

18 U.S.C. § 1962(d)

v.

RICO Conspiracy

18

U.S.C.

§

1962(c)

Racketeer ing

(1) EDWARD J . MACKENZIE, JR. , 18 U.S.C.

§

1349

Mail Fraud Conspiracy

18 U.S.C. 1956(h)

Money Laundering Conspiracy

18

U.S.C.

§

1951

Extor t ion

18 U.S.C.

§

1343

Wire

Fraud

Defendant.

18 U.S.C. 2(a)

Aiding

and

Abet t ing

18 U.S.C. §§

981,

982,

963,

28 U.S.C. 2461

Criminal

For fe i t u re

INDI TMENT

THE UNITED STATES

GRAND

JURY in

and

fo r the

Dis t r i c t

of

Massachuset ts

charges

tha t :

1

Case 1:13-cr-10149-FDS Document 5 Filed 05/21/13 Page 1 of 44



COUNT ONE

(Racketeering Conspiracy)

At a l l

t imes re levant to th i s

Indictment:

THE

ENTERPRISE

1. The Boston Society of

the

New

Jerusalem

was chartered

in

1823 as one of the f i r s t

Swedenborgian

churches in

Massachusetts.

The Boston

Society of

the

New

Jerusalem, Inc .

here inaf ter ,

BSNJ ) was

a

char i tab le re l ig ious

non-prof i t

corporat ion

es tabl ished under the

laws of

the

Commonwealth

of

Massachusetts which operated as

a

church.

BSNJ

es tabl ished

Bostonview

Corporation, Inc. here inaf te r , BVC ) , which

does

business in

Massachusetts

as

a non-prof i t corporat ion,

for the

spec if ic purpose

of

holding t i t l e to proper ty

loca ted

a t 130-140

Bowdoin

Street , Boston, Massachusetts.

The

130-140

Bowdoin

St ree t

proper ty

encompassed

both

the

Boston

Society

of the

New

Jerusalem

church

and an

approximately

18-story apartment

bui lding with

approximately

145 res iden t ia l

ren ta l

uni t s

here inaf ter , "BVC Apartments"). These

ren ta l un i t s

generated

net

income of approximately $1.4 mil l ion per year. Each year

since

in or

about 2006,

BVC has

remit ted

i t s

net

income

to BSNJ.

2. BSNJ was run by a Board

of

Trustees, which was elec ted

by the church

members. The

Board of Trustees

was

responsible

for

decisions

regarding BSNJ's f inances, the col l ec t ion and

2




di s t r ibu t ion

of

a l l

funds

for the

support of publ ic worship or

specia l programs, the maintenance of f inancia l records , and the

preparat ion of

a

budget.

As

of in or

about

2003,

BSNJ

a lso had

a Director

of Operat ions,

who

had respons ib i l i ty and

author i ty

for changes to

the

phys ical

plant

of the

church. BVC was run

by

a

Board

of

Directors

and was a wholly-owned subsid iary of BSNJ.

BSNJ,

together

with

i t s wholly-owned subsidiary, BVC wil l be

re fer red to here in

as the Church.

3 . The Church cons t i tu ted an enterpr i se as def ined

by

Ti t l e

18, United

Sta tes

Code,

Section 1961(4) , t ha t i s , an

associa t ion

in

fac t of e n t i t i e s

(here inaf te r ,

the ente rpr i se ) .

The ente rpr i se cons t i tu ted

an

ongoing organiza t ion whose members

funct ioned

as

a

continuing uni t for

a common

purpose of

achieving the objec t ives of the

enterpr ise .

This

ente rpr i se was

engaged

in ,

and

i t s

a c t i v i t i e s

affec ted,

in te r s t a te

and

foreign

commerce.

4 . The Church i s

an exempt

organizat ion under Interna l

Revenue

Code Section

501

(c)

(3)

(here inaf te r , IRC Sect ion

SOl(c) ( 3 ) ) .

Under

the U. S. tax code, as an exempt

organizat ion ,

the Church i s

prohibi ted

from

engaging

in

ac t iv i t i e s

t ha t

resu l t in inurement of the

Church's

income or

asse ts

to

ins iders .

The

prohibi t ion aga ins t

inurement to

3




ins iders i s

absolute;

therefore , any amount

of inurement

to

ins iders

i s

poten t ia l ly

grounds

for loss of tax-exempt s ta tus .

THE DEFENDANT

5. EDW RD J . MACKENZIE JR.

54,

became

a member

of the

Church in approximately

September

2 2i in 2003, MACKENZIE

became

the

Church's Director of Operations, a sa la r i ed

pos i t ion

tha t was

created especial ly for him

and

which he s t i l l

holds.

6. MACKENZIE

was an

of f i ce r of

BSNJ

and

a

Director of

BVC

In

Massachusetts, off icers

and

di rec tors of

non-prof i t

corporations

must

act in

good fa i th and

exerc ise

f iduciary

dut ies

of care

and loya l ty .

Pursuant

to

Massachusetts

General

Law Chapter 180,

Section

6C, a

director

sha l l perform

his

dut ies as

such in good fa i th and

in a manner

he

reasonably

bel ieves

to

be

in

the

bes t

in te res t

of the

corporat ion,

and

with

such

care

as

an

ord inar i ly prudent person in a l ike pos i t ion

with

respect to

a simi lar

corporat ion would use

under

s imilar

circumstances.

A di rec tor may

not improperly

benef i t from

t ransac t ions with the corporat ion.

THE RACKETEERING CONSPIRACY

7.

From

a t

leas t

as ear ly as

in or

before September

2002,

and continuing through a t leas t in or about December 2012/

within

the Dis t r ic t of Massachusetts and elsewhere / EDW RD J .




MACKENZIE JR. defendant herein

l

and others

known

and

unknown

to

the

Grand

Jury

being persons employed

by

and associa ted with

the Church

an

ente rpr i se engaged

l

and the

ac t iv i t i e s

of

which affec ted

in te r s ta te and foreign commerce did unlawful ly

and

knowingly

conspire confederate

and

agree

to vio la te

Ti t le

18

United

Sta tes Code

I

Sect ion 1962 c), tha t i s , to

conduct

and

par t i c ipa te ,

d i r ec t ly

and

indirect lYI in the conduct

of

the

a f fa i r s of the ente rpr i se through a pat t e rn of

racketeer ing

ac t iv i ty . The

pat t e rn of

racketeer ing act ivi tYI

as tha t

term i s

def ined by Ti t le 18,

United Sta tes Code,

Sect ions 1961 1) and

1961 5)1 through

which

MACKENZIE and his co-conspirators

agreed

to

conduct

and par t i c i pa t e

d i r ec t ly and

i nd i rec t l y in

the

conduct

of the a f fa i r s of

the

ente rpr i se

consis ted of

mult ip le

ac ts : a)

indic table

under Ti t l e 18, United

Sta tes Code

Sect ion

1343

wire

fraud)

i

b)

indic table

under

Ti t l e

18

United

Sta tes

Code

Section 1341 mail fraud) i c)

indic table

under

Ti t le 18

United

Sta tes Code

Sect ion

1956 money laundering) i

(d)

indic table

under Ti t le 18 United

Sta tes

Code Sect ion 1951

extor t ion) ; and

e)

involving bribery chargeable under Sect ion

39 of Chapter 271 of the

Massachusetts

General Laws.

8. I t

was par t of

the

conspiracy tha t MACKENZIE

agreed

tha t

a conspi ra tor would commit a t

l e a s t two

ac ts of

5




racketeering ac t iv i ty in

the

conduct

of the

a f fa i r s of

the

enterpr ise .

OBJECTS OF

THE CONSPIRACY

9.

I t was a goal

of

the conspiracy for

M CKENZIE

and his

co-conspi ra tors to become members of the ente rpr i se

and

obta in

power and influence within the ente rpr i se so tha t

M CKENZIE

and

his co-conspi ra tors could defraud the Church of i t s considerable

f inancia l holdings

and

pro f i t

from t ransac t ions

involving the

Church.

10. Once

M CKENZIE

and

his

co-conspi ra tors were in

posi t ions

of author i ty within the

ente rpr i se , they ca r r ied out

a

scheme to defraud

the Church and

to obta in

money and

property

from the Church

by means

of fa lse and f raudulent

pretenses,

representa t ions and promises, to enrich themselves

and

others

a t

the

expense

of the

Church,

and

to

personal ly enr ich

themselves

by so l i c i t i ng and accepting bribes and kickbacks from vendors

doing

business with the Church.

MANNER AND MEANS

OF

THE CONSPIRACY

I t was a par t of the

conspiracy

that :

11. M CKENZIE and co-conspi ra tor Thomas J . KENNEDY

another

new Church member

knew

tha t the Church had only a

small number of

voting

members, many of

whom

were

e lder ly .

M CKENZIE became

a

fu l l

voting member of the Church

in

o r

about




September 2002.

Shor t ly

af t e r jo in ing the Church, MACKENZIE and

KENNEDY devised a plan to gain control

of

the Church so

tha t

they could defraud

the

Church of i t s considerable f inancia l

holdings

and

pro f i t from

t ransac t ions involving

the Church.

12. Accordingly, MACKENZIE and

KENNEDY

devised a

scheme

to

gain contro l of the Church by, among

other

things:

a.

Inducing the then-Reverend to endorse MACKENZIE

and

KENNEDY s

plan

to take

cont ro l

of the Church by

promising,

and

subsequent ly grant ing, him

substant ia l

remunerat ion and

autonomy

with in the

Church;

and

b. Recrui t ing and using f r iends and

family,

some of

whom

had

no i n t e r e s t in

or

awareness of,

the Church

and

i t s teachings,

to

become

members, and

crea t ing

phony membership appl ica t ions for

other

new Church

"members" who

had

no idea

they

had

"applied" for

membership in order to es tab l i sh a voting maj o r i

ty

to

e lec t themselves in to pos i t ions

of

author i ty

within

the Church.

13.

At

the

annual

Church

members

meeting in or about

May

2003, MACKENZIE and

KENNEDY assembled

a

suf f ic ien t

voting bloc

to

take

control

of

the

Church. Once

in cont ro l in

or

about

2003,

MACKENZIE KENNEDY and the i r co-conspirators began moving

to

consol idate

and fo r t i fy

the i r

power, including, but not

l imited

to

the following:

(a)

removing cer ta in incumbent

Trustees

and

Church of f i c i a l s

who

were

perceived

as

obstacles;

(b)

seceding

from

the

General Convention

and other

umbrella

and

parent organizat ions

of the Swedenborgian

Church

in

order

to




obta in

grea te r autonomy;

c) amending the Church 's

by-laws to

give MACKENZIE

and KENNEDY grea te r au thor i ty and con t ro l ;

and

(d) crea t ing

the s a l a r i e d pos i t ion

of

Direc tor of

Operat ions

for the Church

- a p o s i t i o n

fo r which

MACKENZIE was

h i red in

2003 and

cont inued to

hold as of May 2013 and giv ing

the

Direc to r o f Operat ions au thor i ty fo r changes

to

the phys ica l

p lan t

of the

Church.

14. In add i t ion to

conso l ida t ing

t he i r power

within

the

Church,

once

in con t ro l ,

MACKENZIE and h i s co-consp i ra to rs , in

v io la t ion

of

t he i r f iduc ia ry

ob l iga t ions

and

the

Church 's IRC

Sect ion

501(c

(3) s t a tus , began vot ing to provide

themselves

and

t he i r assoc ia tes with subs tan t i a l

f inanc ia l

benef i t s , including,

but no t

l imi ted to : (a) the purchase

of

a t l ea s t

four

new

vehic les

for ,

among others ,

MACKENZIE

KENNEDY

and

a r e l a t i ve

of MACKENZIE;

(b)

cash

awards

fo r

MACKENZIE s

family

members;

c )

a

$50,000

loan to

MACKENZIE

to pay

h i s

persona l l ega l

b i l l s ; and (d) t u i t i on grants

to

family members

of

KENNEDY.

15. On

o r

about

December 12, 2003, the

Church

ente red i n to

a

f ive -year employment agreement

with

MACKENZIE

to be the

Church 's

Direc tor

of Operat ions , a pos i t ion

t ha t

had not

previous ly

ex is ted .

The agreement

provided

MACKENZIE

with a

s t a r t i ng

sa l a ry

of $100,000,

annual

sa la ry inc reases

in

accordance with

the Consumer Price

Index,

performance bonuses,

a

8




re t i rement plan, heal th

insurance,

and

four weeks of

paid

vacat ion (plus

11 paid

holidays) .

In September

2006,

the

Board

of Trustees agreed to renew MACKENZIE s employment agreement for

another f ive years ef fec t ive

December

2008,

and

continuing

through

December

2013. In

2012,

MACKENZIE s salary

and

compensation as the Church's

Director of

Operations

was

approximately

$200,000.

16.

Once

in power,

M CKENZIE began

to systemat ica l ly loot

the Church of i t s

considerable

f inancial assets

through

a

combination

of

fraud,

decei t ,

extor t ion, the f t ,

and

bribery.

Moreover,

M CKENZIE

int imidated

and threatened

individuals

who

were employed

by and did work a t the Church by in

part , among

other things,

providing them with signed copies of his 2003

autobiography,

St ree t So ld ie r : My

L i f e

as

an Enforcer f o r

Whi

tey

Bulger

and

the

oston

I r i s h

Mob

here inaf te r ,

St ree t

S o l d i e r

In

St ree t So ld ie r , M CKENZIE admitted

to

a lengthy

criminal his tory,

including

burglary,

robbery, armed assaul t ,

and

narcotics t raff icking.

All in violat ion

of Ti t le 18, United Sta tes Code,

Section

1962 (d) .

9




COUNT TWO

(Racketeering)

17.

paragraphs

1-6

and 9-16

are

res ta ted

herein and

incorpora ted

by

reference .

18. From a t l ea s t

in

or

before

September

2002 and

cont inuing through a t l e a s t i n o r about December 2012, in

the

Dis t r i c t

of Massachusetts and elsewhere, EDW RD

J MACKENZIE

JR . , defendant herein , together wi th o thers , known and

unknown

to the

Grand

Jury,

being persons

employed by and associa ted

with

the Church,

did

unlawful ly and knowingly

conduct

and

par t i c ipa te , d i rec t ly and

ind i rec t ly ,

in the conduct of the

a f f a i r s

of the Church,

an

ente rpr i se which was engaged in , and

the

ac t iv i t i e s

of which

affec ted , i n t e r s t a t e

and foreign

commerce, through

the pa t t e rn of

racketeer ing

ac t iv i ty

par t i cu l a r l y descr ibed below in

paragraphs

19

through

56.

R CKETEERING

CT NUMBER ONE

(Space propuls ion

Wire

Fraud)

19.

In o r

about

Spring of 2004, M CKENZIE and KENNEDY

knowingly caused the Church to invest

$200,000

of Church money

in

Flor ida

corpora t ion , Space propuls ion Systems,

Inc.

here inaf ter , "Space propuls ion") .

M CKENZIE

and KENNEDY caused

the Church

to

invest

$200,000 in Space Propuls ion

by

f raudulent ly

misrepresenting tha t the $200,000

was

an

investment, when t was primari ly

means

for

M CKENZIE

and

10




KENNEDY to

enr ich

themselves a t the Church's expense.

In

fac t

MACKENZIE

and

KENNEDY

had an agreement wi

th

Space Propuls ion

tha t the Church's

investment

was condit ional

on an

immediate

$80,000 kickback to

MACKENZIE

and KENNEDY which

MACKENZIE

and

KENNEDY concealed

from

the

Church.

20. rom a t

l eas t

in o r about Spring 2004, to a t

l eas t

on

or about June 8, 2004,

MACKENZIE

and others ,

known

and unknown

to

the Grand

Jury, devised

and

intended to devise the

above-

descr ibed

scheme and

a r t i f i c e to defraud

the Church, and

to

obta in money and

proper ty by

means

of

mater ia l ly

fa lse

and

fraudulent pretenses,

representa t ions and

promises.

21. On

o r about each of

the dates se t for th

below,

in

Boston,

in

the Dis t r i c t

of

Massachusetts,

in

Jacksonvil le ,

in

the Middle Dis t r i c t

of

Florida, and elsewhere, EDW RD

J.

MACKENZIE

JR.

defendant

herein, aided

and

abet ted

by

others,

known

and unknown to the Grand

Jury, for

the

purpose

of

executing

the scheme

and

a r t i f i c e

described

above,

caused to be

t ransmit ted by means of wire

communication

in

in te rs ta te

commerce

the s ignals and

sounds

described

below,

anyone of

which alone

cons t i tu tes the

commission

of

Racketeering Act

11




Number

One, i n v io l a t i on of Ti t l e

18,

United Sta tes

Code,

Sect ions 1343 and

2 (a) :

DATE

DESCRIPTION

1A June

4, 2004 $200,000 wire MA to L

1B

June

7,

2004

$40,000

wire

L

to

M

KENNEDY)

1C

June

8,

2004

$40,000 wire L

to M

MACKENZIE)

RACKETEERING ACT

NUMBER TWO

(College Tuit ion

Mail

Fraud)

22. The Church has long had

a

t u i t i on grant program

in

which

the Church

provided

scholarsh ips and tu i t ion

grants to

the

famil ies

of

Church members. Between approximately

Winter

2005

and August 2008, MACKENZIE f raudulent ly

caused

the Church to pay

approximately $108,980 in t u i t i on payments to

Boston

College and

Quinnipiac

Univers i ty

on behalf

of the chi ldren of

an

execut ive

a t the property

management company

tha t managed the BVC

Apartments here ina f t e r

"Tuit ion

Recipient

#1") .

I t was par t

of the

scheme

tha t MACKENZIE fa l se ly

misrepresented to Tui t ion

Recipient #1 tha t the Church had expanded i t s t u i t i on

reimbursement

program

to non-Church members

when

in fac t

the

Church had not done so.

MACKENZIE

then

encouraged

Tui t ion

Recipient #1 to

apply to

the Church s

t u i t i on

program. In

re tu rn for

using

his

in f luence

to

cause

the

Church

to

improperly

pay

$108,980 in

t u i t i on

payments

on

behal f of

Tuit ion

Recipient

12




1,

MACKENZIE

so l i c i t ed and accepted from Tui t ion

Recipient

1

approximately $20,000

in cash kickbacks.

23.

From

a t

l e a s t as

ear ly as in

or about March

2005,

through

in

or

abou t

Augus

t

2008,

in

the

Dis t r i c t

of

Massachusetts ,

the

Dis t r i c t

of Connecticut,

and

elsewhere,

EDWARD J. MACKENZIE

JR. defendant herein,

aided

and abe t ted

by

others, known and unknown to the Grand

Jury, devised

and

intended

to devise the

above-described scheme

and

a r t i f i c e to

defraud

and obta in

money

and

property by mater ia l ly fa lse

and

fraudulent pretenses,

representa t ions , and

promises.

24.

On

or

about the dates l i s t ed below,

in

the Dis t r ic t

of Massachusetts , the

Dis t r i c t

of Connecticut,

and

elsewhere,

for the

purpose

of

execut ing and

at tempting to

execute the

above-described scheme and a r t i f i c e

to defraud

and obta in money

and

property

by

means

of

mater ia l ly

fa lse

and

fraudulent

pretenses, representa t ions

and

promises,

MACKENZIE

knowingly

caused to be placed in a

post

of f i ce

and authorized

deposi tory

for

mail matter a matter and thing

to

be

sent

and del ivered by

the Posta l

Service, anyone of

which

mail ings

alone cons t i tu te s

the commission of Racketeering Act Number Two,

in

v io la t ion of

Ti t le 18, United Sta tes Code, Sections

1341 and

2 a) :

DATE CHURCH CHECK MAILING

A

January

1, 2006 $15,000 to BC

(ck.

2897)

13




2B

August 3,

2006

$15,000

to

BC

(ck.

3359)

2C

January 4,

2007

$15,000 to BC

(ck. 3701)

2D June

141

2007

15 000

to

BC

(ck. 4064)

2E

January

41

2008

15

000

to

BC

(ck.

4497)

2F

Ju ly

10

1

2008 15 000

to

QU

(ck.

6323)

2G

August

141

2008

18 980

to

BC

(ck.

6362)

TOT L

108,980

RACKETEERING

ACT

NUMBER

THREE

(Check

Stea l ing Mail Fraud)

25.

Between i n o r

about

Apri l

2006

and i n o r

about

June

2008 M CKENZIE and KENNEDY

came

i n t o physica l possess ion o f

seven

checks

made payable to

e i t h e r

BSNJ o r BVC.

M CKENZIE

and

KENNEDY

then

devised a scheme

to

s t e a l the checks

from

the

Church. t was

p a r t

of the scheme t ha t i n orde r to s t ea l the

checks M CKENZIE and KENNEDY crea ted a phony t r u s t BVC

Trus t

M CKENZIE

and KENNEDY used

among o ther

th ings

the

crea t ion

of BVC Trus t

to open

two sham

Sovereign

Bank

accounts

in

the

names

of

BSNJ

and

BVC. When

M CKENZIE

and

KENNEDY

opened

the two

sham

Sovereign Bank accounts

they

provided the bank

with

addresses

over which

M CKENZIE and

KENNEDY had exc lus ive

dominion and con t ro l

This a l lowed

M CKENZIE and KENNEDY

to

conceal

the

scheme to

defraud from the

Church by main ta in ing

con t ro l over the bank s ta tements

and

f inanc ia l records fo r the

two sham

Sovereign Bank accounts .

Once

the

sham Sovereign Bank

accounts

were opened, it was pa r t

of the

scheme t ha t M CKENZIE

and KENNEDY f raudulent ly depos i t ed seven checks

payable

to

the

14




Church I

to ta l ing approximately 168 169.74

1

in to the sham

Sovereign Bank accounts .

After the seven checks were deposi ted

MACKENZIE

and KENNE Y

I

through a se r i e s of f inancia l

t ransact ions tha t were designed a t l e a s t

i n pa r t

to conceal the

fraud

shared

the proceeds .

26. From

a t l eas t

on

or about April

6 I

2006 un t i l a t

l e a s t

on

or about June 20

1

2008

1

a t Boston

Canton

I

and

elsewhere

in

the Dis t r i c t

of

Massachusetts

EDWARD

J MACKENZIE

JR. defendant here in

a ided and abet ted by others known and

unknown to the Grand

Jury

1

devised

and intended

to devise

the

above described scheme

and

a r t i f i c e to defraud and obta in

money

and

proper ty

by mater ia l ly fa lse

and f raudulent pre tenses

representa t ions

and promises.

27.

For the purpose

of execut ing

and at tempting

to

execute

the above descr ibed

scheme

and

a r t i f i c e

to

defraud

and

obta in

money

and proper ty by

mater ia l ly

fa l se

and

f raudulent pre tenses

representa t ions and promises 1 MACKENZIE and KENNE Y

knowingly

caused

to be placed in a

pos t

off i ce

and author ized

deposi tory

for

mail

matter

a

matter

and

th ing

to be

sent

and del ivered by

the Postal Service to wit:

bank

sta tements and other f inancia l

documents between 2006 and 2008 for the sham Sovereign Bank

ccounts in v io la t ion

of Ti t l e 18

United Sta tes Code Sect ions

1341

and 2 a) .

15




R CKETEERING CT NUMBER FOUR

Money

Conspiracy)

28. In

approximately

April 2006

1

M CKENZIE created a sham

t ru s t

Fi l labus te r

Cater ing

Trustfl

(here inaf te r

1

FCT

)

based

on

a

purposeful var ia t ion of the

name of "Fil l-A-Buster

Restaurant which

had been loca ted next

to the

Church for over f

30 years . I t was

par t

of the

conspiracy tha t in crea t ing

FCT

1

M CKENZIE fa l se ly misrepresented on various

documents

tha t an

ex-g i r l f r i end of

his was

the t rus tee

l

of FCT 1

and

a s igna ture

purport ing to be tha t of

his

ex -g i r l f r i end appears on FCT-

re la ted

documents. MACKENZIE s ex-g i r l f r i end

however 1 had

never

heard

of FCT

and was not famil ia r

with the term t rus t ee

1

nor

had

she

ever

signed any document

on behalf

of

FCT. Once the

FCT

was

es tabl ished

M CKENZIE used the fa l s i f i ed FCT documents

to open

a bank

account

in the name of FCT

1

for which

M CKENZIE

had sole signatory author i ty . Once the

FCT

bank

account was

es tabl ished

M CKENZIE

used the account to conceal from the

Church

his a f f i l i a t i on with FCT

1

conceal the proceeds of

Racketeering Acts Numbers Three Eight Fif teen

and

S i x t een

l

and conceal

from

the In te rna l

Revenue

Service

more

than

approximately

316 / 000

in

income

tha t

he

was

paid

by

the

Church

through FCT.

16




29. From

a t

l ea s t in

o r

before

Apri l 2006 and cont inuing

through a t

l ea s t

in o r about

December 2 12 in the Di s t r i c t of

Massachuset ts

and

elsewhere

l

EDWARD

J .

MACKENZIE JR.

defendant

Iere in

l

and

o ther s known

and unknown to the

Grand

Jury I

knowing

t ha t the

prope r ty involved i n f inanc ia l

t ransac t ions represented

the

proceeds of some

form

of

unlawful act iv i tYI did knowingly

conspire , confederate ,

and

agree

to conduct

f inanc ia l

I

r ansac t ions a f fec t ing

i n t e r s t a t e and fore ign commerce,

which

i n fac t involved

the

proceeds

of

mail

fraud,

i n v io la t ion

of

Ti t l e

18

1

United Sta tes

Code Sec t ion

1341, and

commercial

br ibery , i n v io l a t i on of Sec t ion 39 of

Chapter

271 of

the

Massachuset ts General Laws knowing

tha t the

t r ansac t ions were

designed in whole and in pa r t to conceal and di sgu i se the

na ture , the

loca t ion

l

the source , the ownershipi and the cont ro l

of

the

proceeds

of

mail

fraud

a l l

in

v io l a t i on

of

Ti t l e

18,

United

Sta tes Code, Sec t ion 1341

and commercial

br iberyl

in

v io la t ion

of Sec t ion

39 of Chapter

271 of

the

Massachuset ts

General Laws

in

v io l a t i on of Ti t l e 18, United Sta tes

Code

Sect ions 1956(h)

and

1956(a) (1) B) i ) .

RACKETEERING

CT NUMBER

FIVE

(Plumber

#1

Commercial

Bribery)

30. In o r about

Summer 2006

I the Church h i red

a

l a rge

commercial plumbing company here ina f t e r I \\CPC

t

to replace

the

17




piping in the

BVC Apartments.

MACKENZIE a lso caused the

Church

to h i re "Plumber #1,"

a

one-employee

plumbing

operat ion, to

"oversee" CPC

despi te

the fac t tha t Plumber

#1'

s

hi r ing

was

unnecessary

to

complete

the

pipe replacement

job.

Between July

2006 and October 2007,

the Church

paid

Plumber

#1 approximately

$123,808 to "oversee" the pipe replacement job. During that

same period,

in

re turn

for using

his influence within

the

Church

to

help

Plumber #1

maintain

and obta in work from

the Church,

MACKENZIE

so l i c i t ed and accepted thousands of

dol la rs in

cash

kickbacks from Plumber #1.

31.

From

a t l eas t in

o r

about

Summer 2006,

un t i l a t l eas t

in

or

about October 2007, in

the

Dis t r i c t

of

Massachusetts, in

re la t ion

to

t ransac t ions and matters concerning the business

a f fa i r s of

an employer,

pr inc ipa l

and

benef ic ia ry to wit , the

Church, and

as

an

agent

and

f iduciary

of the

Church,

EDWARD

J .

MACKENZIE

JR., defendant

herein,

so l ic i ted accepted, and

agreed to accept payments from Plumber #1,

who

was not

an

employee, principal

and benef ic iary

of the Church, upon

an

agreement and understanding

tha t such

payments would

inf luence

MACKENZIE s

conduct, in

v io la t ion of

Sect ion 39 of Chapter 271

of the

Massachusetts General Laws.

18




RACKETEERING CT NUMBER SIX

(Floorer #1 Commercial Bribery)

32.

Between 2006 and 2011

1

"Floorer 1'1 was the

owner

of

a

grea te r

Boston

discount

carpet

and

f loor ing

company

who

was

paid

approximately $356

/

000 by the Church for numerous carpet and

f loor ing- re la ted jobs. During tha t

same

period

in

re tu rn for

using

his inf luence with in the

Church to

help Floorer #1

obta in

and maintain f loor ing- re la ted

work

a t the

Church MACKENZIE

knowingly caused

Floorer

#1 to i n f l a t e his bids for work a t the

Church

by so l i c i t i ng

and

accept ing approximately $116

/

650 in

cash kickbacks

from Floorer

#1.

33.

From a t l ea s t in o r about September 2006

1

un t i l a t

l ea s t

in or about

December in the Di s t r i c t of

1assachusetts

in

r e l a t i on

to t ransact ions and

matters

concerning

the business

a f f a i r s

of an

employer

1

pr inc ipa l

and

benef ic ia ry

to

wit ,

the

Church,

and as

an

agent and

f iduc ia ry

of

the

Church, EDWARD J. MACKENZIE JR. defendant herein

so l i c i t ed accepted, and agreed

to

accept payments

from

Floorer

11

who

was not an employee

1

pr inc ipa l

1

and benef ic iary of the

Church

1

upon an agreement o r unders tanding tha t such payments

would

inf luence

MACKENZIE s

conduct

1

in v io la t ion

of

Sect ion

39

of

Chapter

271 of the Massachusetts

General

Laws.

19




RACKETEERING

CT

NUMBER

SEVEN

(Aquarium

Owner

Commercial Bribery)

34.

Between 2005 and 2011,

Aquarium

Owner, the

owner

of

a

grea te r

Boston

f i sh

and aquarium

r e t a i l

s tore

b i l l ed

the

Church,

on average, approximately $25,000 - $30,000

per

year for

aquarium serv ices and associa ted

maintenance.

In approximately

March 2007, MACKENZIE f raudulent ly caused the Church to

pay for

a

high-end aquarium i n s t a l l ed a t MACKENZIE s

residence in

weymouth,

Massachusetts by Aquarium

Owner.

From the

time

the

aquarium was i n s t a l l ed a t MACKENZIE s

residence

in

2007, through

in

or

about

2011,

in

re turn

for using

his influence within

the

Church to

help

Aquarium

Owner

obta in

and

maintain

aquarium-

re la ted work a t

the

Church, MACKENZIE knowingly caused Aquarium

Owner

to in f l a te his bids

for

work a t

the Church

by so l i c i t i ng

and

accepting

from Aquarium Owner

approximately

$3,000 per

year

in concealed br ibes and kickbacks tha t consis ted of the

maintenance and replacement work performed on the aquarium

ins ta l led

in

MACKENZIE s

residence

( for

which Aquarium Owner

never charged MACKENZIE

.

35.

From a t

l e a s t

in

or about March 2007, un t i l a t l eas t

in

or

about

December

2011,

in

the

Dis t r i c t

of

Massachusetts ,

in

re la t ion to t ransac t ions

and

matters

concerning

the business

a f fa i r s of

an employer,

principal

and benef ic iary

to wit , the

20




Church,

and

as an agent

and

f iduciary

of the

Church, EDWARD J

MACKENZIE JR. defendant herein,

so l i c i t ed accepted, and

agreed to accept th ings of value , to wit ,

an

aquarium i n s t a l l ed

a t his

residence

and re la ted

maintenance

serv ice and

par ts /accessor ies from

Aquarium

Owner,

who

was

not

an

employee,

pr inc ipa l and

benef ic iary of

the

Church,

upon

an agreement or

understanding

tha t such

th ings

of

value would inf luence

MACKENZIE s conduct,

in v io la t ion of Section

9

of Chapter 271

of

the

Massachuset ts

General Laws.

R CKETEERING CT NUMBER

EIGHT

(Carpenter #1

Commercial

Bribery)

36. Carpenter #1

i s a

self-employed carpenter

who

has run

his own commercial and res ident i a l general cont rac t ing company

in

grea te r

Boston

for

more

than

twenty years .

Between

approximately

Summer

2007

and

December

2007, in

re turn

for

using

his

inf luence within the

Church to he lp Carpenter #1

obta in

and

mainta in

genera l

cont rac t ing

work

a t the

Church, MACKENZIE

knowingly caused Carpenter #1 to i n f l a t e

his

bid fo r

work

a t the

Church by

so l i c i t i ng

and accepting approximately $24,000 in

kickbacks from Carpenter #1,

some

of which MACKENZIE di rec ted be

in

the

form

of

checks

payable

to

Fi l l a bus t e r

Catering,

which

MACKENZIE

caused to

be deposi ted in to the

FCT account .

21




37. From a t

l e a s t

in or about August 2007, unt i l

a t

leas t

in

or

about

December

2007, in the Dis t r i c t of

Massachusetts ,

in

re la t ion to t ransac t ions

and

matters

concerning

the business

a f fa i r s

of

an employer, pr inc ipa l and benef ic iary

to wit , the

Church, and

as

an agent and f iduciary of the Church,

EDWARD

J

MACKENZIE JR. defendant herein,

so l ic i ted accepted, and

agreed

to accept payments from Carpenter 1,

who was

not

an

employee,

pr inc ipa l and

benef ic ia ry

of the

Church, upon

an

agreement

or understanding tha t such payments would inf luence

MACKENZIE s

conduct,

in v io la t ion

of

Section

39 of

Chapter 271

of

the

Massachusetts

General Laws.

R CKETEERING

CT NUMBER NINE

(Carpenter #2

Commercial Bribery)

38. Carpenter #2

i s

a

self-employed

carpenter who has

run

his own general cont rac t ing

company

in

grea te r

Boston for

more

than two decades. Between

approximately

May 2007 and December

2010, Carpenter

#2 was paid

approximately

$96,345 by the

Church.

In

re turn for

using

his

influence within the

Church to help

Carpenter #2 obta in

and

maintain

general cont rac t ing work a t the

Church,

MACKENZIE so l i c i t ed

and

accepted

cash

and in-kind

kickbacks

from

Carpenter

2,

to

wit ,

a t

leas t

approximately

$20,500 in cash as wel l as carpent ry work tha t

was

paid

for

by

22




the

Church

but was

performed

by Carpenter 2 a t the residences

of

M CKENZIE

and a family

member of MACKENZIE.

39.

From

a t l eas t in or

about May

2007, un t i l

a t

leas t in

or about December

2010, in the

Dis t r i c t

of

Massachusetts ,

in

re la t ion to

t ransact ions and

matters

concerning

the

business

a f fa i r s of an

employer,

pr inc ipa l , and benef ic iary ,

to wit , the

Church, and as an

agent

and f iduciary of

the Church,

EDW RD J

MACKENZIE, JR. defendant herein,

so l ic i ted , accepted, and

agreed

to

accept payments from Carpenter 2, who was not an

employee, pr inc ipa l , and benef ic iary of the

Church,

upon an

agreement or

understanding tha t

such

payments would inf luence

MACKENZIE s conduct, in vio la t ion of Section

39

of

Chapter 271

of

the

Massachusetts General Laws.

R CKETEERING

CT NUMBER

TEN

(Carpenter #2 Extort ion)

40.

Not

l a t e r than 2009, M CKENZIE gave

Carpenter #2 a

signed copy of Stree t Soldier In or about December 2010, in

connection

with a

job a t the Church, when Carpenter 2 i n i t i a l l y

attempted to provide M CKENZIE with only

a

$3,000 ( instead

of

the prev iously

agreed-upon

$6,000) cash

kickback,

M CKENZIE

swore

a t

Carpenter

2,

banged

on

the

hood

of

Carpenter

2's

car,

and put Carpenter 2 in fear

for his physical

safe ty. At tha t

poin t , Carpenter

#2

gave M CKENZIE an addi t ional

$3,000

in

cash.

23




41. From in

or

about a t

l e a s t 2009

and continuing un t i l in

or about

December

2010, within the

Dis t r i c t

of

Massachusetts ,

EDWARD

J

MACKENZIE JR.

defendant

here in , d id

obstruc t ,

delay,

and af fec t commerce and the movement of ar t i c l es and commodities

in commerce by

extor t ion, as those

terms

are defined in

Ti t le

18, United Sta tes Code,

sec t ion 1951, tha t i s ,

MACKENZIE

obtained

property,

to

wit ,

United

Sta tes currency,

from

Carpenter 2

with Carpenter 2's consent,

which

consent was

induced by the wrongful use of ac tua l and threatened force ,

violence, and fear , in

v io la t ion

of Ti t l e 18, United

Sta tes

Code,

Section 1951.

RACKETEERING ACT NUMBER ELEVEN

(Boiler

Replacement Wire

Fraud)

42. In

approximately

December 2010,

af t e r being advised

tha t MACKENZIE

required

a kickback of approximately 10

on

a l l

work done a t the Church, the owner of CPC in f la ted

the

bid he

submitted to the Church

for

a

boi le r replacement job to account

for

the

10 kickback to MACKENZIE.

In

re turn for

using his

inf luence within the Church to help CPC obta in

and

mainta in the

boi le r

replacement job, MACKENZIE knowingly caused CPC

to

i n f l a t e

i t s

bid for

work

a t

the

Church by

so l i c i t ing

and

accepting

an

approximately

27,400

cash kickback from the

owner

of

CPC.

24




43.

From

a t

l e a s t

in or

about

December 2010, to

a t

l ea s t

on or

about

October/November 2011, MACKENZIE

devised

and

intended

to devise the

above-described

scheme

and

a r t i f i c e to

defraud

the

Church, and to obta in money and proper ty by means of

mater ia l ly fa lse and

fraudulent

pre tenses

representa t ions

and

promises.

44.

On o r

about each of

the

dates se t

for th below,

in

the

Dis t r i c t of Massachusetts and elsewhere,

EDW RD

J MACKENZIE

JR. defendant herein, aided and abet ted by others

known and

unknown to the Grand Jury, for the

purpose

of execut ing

the

scheme

and a r t i f i c e

described

above,

caused

to be t ransmi t ted by

means

of

wire

communication in in te r s ta te

commerce the writ ings,

s ignals

and

sounds described

below, a n y o n e

of which

alone

cons t i tu te s the

commission

of Racketeering

Act Number

Eleven, in

vio la t ion

of

Ti t l e

18,

United

Sta tes

Code,

Sections

1343

and

a)

DESCRIPTION

l lA

12/20/2010

a.m.

E-mail

from CPC

to

VC

IlB

12/20/2010

p.m.

E-mail from

CPC

to

VC

25




RACKETEERING

ACT NUMBER TWELVE

(Boiler Replacement Commercial Bribery)

45. Paragraph 42 i s r es ta ted here in and incorporated by

reference.

46. From a t l e a s t in or

about

December 2010, to

a t

leas t

on

or

about October/November 2011,

in the Dis t r ic t of

Massachusetts ,

in

re la t ion

to

t ransac t ions

and

matters

concerning

the business a f f a i r s

of

an employer,

pr inc ipa l and

benef ic iary ,

to

wit, the

Church, and as an agent and f iduciary

of the

Church,

EDWARD

J .

MACKENZIE, JR.,

defendant

herein,

so l i c i t ed accepted, and

agreed

to

accept

payments from

the

owner

of CPC and

the owner's

associa te

who were

not

employees,

pr inc ipa ls

and

benef ic ia r ie s of the

Church,

upon an agreement

or understanding tha t such payments would

inf luence MACKENZIE s

conduct,

in vio la t ion of

Section

39 of Chapter 271 of the

Massachusetts General

Laws.

RACKETEERING

ACT NUMBER THIRTEEN

(Booster Pump Wire

Fraud)

47.

In or

about

2011, a f te r being

advised

again tha t

MACKENZIE

required

a

kickback of

approximately 10 on

a l l work

done a t the

Church,

the owner of CPC in f l a t ed the bid he

submitted

to the Church

for a boos ter pump job

to

account for

the 10

kickback

to

MACKENZIE.

In

re turn for using

his

inf luence within

the

Church

to help

CPC

obta in and maintain the

26




booster pump job, MACKENZIE knowingly

caused

P to i n f l a t e i t s

bid

for

work a t the Church by so l i c i t i ng

and

accept ing

an

approximately 9,400 cash kickback from the owner

of

CPC

48. From a t

l e a s t

in or

about

Ju ly 2011,

to

a t

l e a s t on o r

about

August 2011, MACKENZIE devised and intended to devise the

above-descr ibed scheme

and

a r t i f i c e to

defraud the

Church, and

to obta in

money and

proper ty

by

means

of mater i a l ly fa l se and

f raudulent

pretenses

representa t ions and promises.

49. On or about each of

the

dates se t for th

below,

in

the

Dis t r i c t

of Massachusetts and

elsewhere,

EDWARD

J

MACKENZIE

JR. defendant here in , aided and abet ted by others known

and


Jury,

for the

purpose

of execut ing

the

scheme

and a r t i f i c e

descr ibed

above, caused to be t ransmi t ted by

means

of

wire

communication in

i n t e r s t a t e

commerce the wri t ings

s ignals

and sounds

descr ibed

below,

a n y o n e

of

which

alone

cons t i tu te s the

commission

of Racketeer ing Act Number Thirteen,

in v io la t ion of Ti t l e 18,

United

Sta tes

Code,

Sec t ions

1343

and

2 (a) :

DESCRIPTION

13A

7/12/2011

E-mail from P

to

Church

13B

8/4/2011 E-mail

from P

to

Church

3C

8/4/2011 E-mail from

P

to

MACKENZIE

13D

8/10/2011

E-mail from

Church to

P

13E

8/10/2011

E-mail from P

to Church

27




R CKETEERING

CT NUMBER

FOURTEEN

(Booster Pump Commercial Bribery)

50.

Paragraph

47 i s res ta ted here in and incorporated by

reference.

51.

From

a t l e a s t in or

about

July 2011, un t i l a t l eas t in

or

about

August 2011, in the

Dis t r i c t

of Massachusetts , in

r e l a t i on to t ransac t ions

and

matters concerning the business

a f fa i r s of

an employer,

pr inc ipa l

and

benef ic iary to wit , the

Church, and

as

an agent and f iduciary

of the Church, EDWARD

J

MACKENZIE

JR.

defendant

herein,

so l ic i ted

accepted,

and

agreed to

accept payments from the

owner

of

CPC and the

owner 's

associa te who

were

not employees, pr inc ipa l s and

benef ic ia r ies

of the Church, upon an

agreement

or understanding tha t such

payments would inf luence

MACKENZIE s

conduct,

in

vio la t ion of

Section

9 of Chapter 271

of

the Massachusetts General Laws.

R CKETEERING CT NUMBER

FIFTEEN

(Painter #1

Wire

Fraud)

52. In o r

about

2009, MACKENZIE asked Pain ter #1,

a

long-

t ime f r i end

of

his to submit a bid for pa in t ing work

a t the

Church, despi te the fac t

tha t Painter #1

had l i t t l e

or

no

previous pain t ing experience .

Between approximately May 2009

and October 2009, Pain ter #1' s company

was

paid approximately

$127,129 by the Church, including

payment

for pain t ing work tha t

Pain ter #1

never

performed but for which the Church,

a t

28




MACKENZIE s direc t ion, was bi l led .

In

re turn

fo r

using

his

inf luence within

the Church to he lp Pain ter 1 obta in

and

mainta in

the pain t ing work

a t

the Church,

MACKENZIE knowingly

caused Pain ter

1

to

i n f l a t e

her b ids for

work

a t the Church by

so l i c i t i ng

and accepting a t

l eas t

approximately $24,000

in

kickbacks from

Pain ter 1 and Pain ter l ' s associa tes ,

a por t ion

of which MACKENZIE

deposi ted

in to

the

F T account .

53. From a t

l eas t

in or

about May 2009,

to a t l eas t in or

about October

2009,

MACKENZIE devised and intended to devise the

above-descr ibed scheme

and a r t i f i c e

to

defraud the Church, and

to

obta in

money

and proper ty by means of

mater ia l ly fa lse and

f raudulent

pretenses , representa t ions

and

promises.

54. On or

about

the

date

se t for th

below, in

the Di s t r i c t

of Massachuset ts and elsewhere,

EDWARD J. MACKENZIE JR.

defendant

herein,

aided

and

abet ted

by

others ,

known

and

unknown

to the Grand Jury, for the purpose of execut ing the

scheme

and

ar t i f i ce descr ibed above,

caused to

be t ransmi t ted by

means

of

wire

communication in

i n t e r s t a t e

commerce the

fol lowing

wri t ing ,

signal and sound, in

v io l a t i on

of Ti t l e 18,

United Sta tes Code,

Sect ions 1343 and 2(a) :

DES RIPTION

9/1/2009 E-mail from

MACKENZIE

to Pain ter 1

29




R CKETEERING

CT NUMBER SIXTEEN

(Painter #1

Commercial

Bribery)

55. Paragraph 52 i s res ta ted

here in and incorporated

by

reference.

56. From a t

leas t in

or about May 2009, un t i l a t l eas t in

o r about October 2009,

in

the Dis t r i c t of Massachusetts ,

in

re la t ion to t ransac t ions and

matters

concerning

the

business

a f fa i r s

of

an

employer,

principal ,

and benef ic iary , to wit, the

Church,

and as an agent and f iduciary of the

Church,

EDWARD J

MACKENZIE JR.

defendant

herein,

so l ic i ted ,

accepted,

and

agreed to accept payments from Painter

#1

and Painter

l ' s

associa tes , who were not

employees,

principals ,

and

benefic iar ies

of

the

Church, upon an

agreement

or understanding

that

such

payments would influence MACKENZIE s conduct, in

violat ion

of Section 39 of

Chapter

271 of the

Massachusetts

General Laws.

All in

v io la t ion

of Ti t le 18, United Sta tes Code, Sections

1962 (c)

30




OUNT THREE

College Tuit ion Mail

Fraud

Conspiracy)

57. As

se t

fo r th above in paragraph 221 which i s

re s ta ted

he re in and incorpora ted

by

re fe rence from

a t

l ea s t

in

o r

about

March

2 5 through a t

l ea s t in o r

about

August

2 8

in the

Di s t r i c t of

Massachuset ts

the D i s t r i c t of

Connect icut

and

elsewhere

EDWARD

J. MACKENZIE

JR.

defendant r in

l

with

the

i n t e n t

to

defraud

combined

conspired

confederated

and agreed

i

th o ther persons known and unknown

to

the

Grand

Jury,

to

devise

the

above-descr ibed scheme and a r t i f i c e

to

defraud and

obta in money and proper ty by mater i a l ly

fa l se

and

f raudulent

pre tenses r ep resen ta t ions and promises .

58. For the purpose of execut ing and

a t tempt ing

to

execute

the above-descr ibed scheme

and

a r t i f i c e to

defraud and obta in

money and prope r ty by mater i a l ly

fa l se

and f raudulent pre tenses

r ep resen ta t ions

and

promises

MACKENZIE and

o ther s known

and

unknown to

the

Grand Jury knowingly caused to

be

placed in

pos t of f ice and author ized depos i tory

for mail

mat te r mat te r

and th ing

to

be sen t and de l ive red by the Pos ta l Serv ice

to

wi

t : t u i t i on payment checks

from

the

Church to Boston College

and

Quinnip iac

Univers i ty .

Al l i n v io l a t i on of Ti t l e

18, United

Sta tes Code Sect ion

1349.

31




COUNT

FOUR

(Check

Steal ing Mail

Fraud Conspiracy)

59.

s

se t for th above in paragraph 25,

which

i s re s ta ted

here in

and

incorporated

by

reference ,

from a t l eas t

on

or about

Apri l

26, 2006, un t i l

a t

l eas t

on

or about June 20, 2008, a t

Boston,

Canton,

and elsewhere in the Dis t r i c t

of Massachusetts ,

EDWARD J.

MACKENZIE JR. defendant herein , with the

in tent

to

defraud, combined, conspired, confederated, and agreed with

other

persons, known

and unknown to the Grand

Jury,

to devise

the

above-described

scheme and a r t i f i c e

to defraud

and obta in

money and

proper ty

by mater ia l ly

fa l se

and

f raudulent pre tenses ,

representa t ions and promises.

60. For the purpose of

execut ing

and at tempting to execute

the above-descr ibed scheme

and

a r t i f i c e to defraud and

obta in

money

and proper ty

by mater ia l ly

fa l se and f raudulent pre tenses ,


promises,

MACKENZIE and others

known

and

unknown to the Grand Jury, knowingly caused

to

be placed in

a

pos t

off i ce and

author ized depos i tory

for mail

matter

a

matter

and

th ing to be

sent and

del ivered

by the

Pos ta l

Service, to

wit: bank sta tements and other f inancia l

documents

between 2006

and

2008

for

the

sham

sovereign

Bank

accounts .

All in

vio la t ion

of Ti t le 18, United Sta tes Code, Sect ion

1349.

32




COUNT

FIVE

(Money Laundering Conspiracy)

61. As se t for th

above in

paragraph 28, which i s

res ta ted

herein

and

incorporated

by

reference ,

from

a t

l e a s t

in

or

before

April 2006 and continuing through a t l e a s t in or about

December

2012, within the Dis t r i c t

of

Massachusetts and elsewhere, EDWARD

J MACKENZIE JR. defendant

herein ,

and others known and

unknown

to the

Grand Jury,

knowing

t ha t

the proper ty

involved in

f inancia l

t ransact ions represented

the

proceeds

of some

form

of

unlawful ac t iv i ty did

knowingly

conspire,

confederate , and

agree to conduct f inancia l t ransac t ions

a f fec t ing i n t e r s t a t e

and

foreign commerce, which

in

fac t

involved

the proceeds of

mail fraud,

in v io la t ion of

Ti t le 18, United

Sta tes

Code,

Sect ion 1341, and

commercial bribery in vio la t ion

of

Sect ion

39

of

Chapter 271

of

the Massachusetts General Laws, knowing tha t

the t ransact ions were designed

in

whole and

in

pa r t to conceal

and

disguise

the

nature , the

loca t ion

the

source,

the

ownership,

and the control of the proceeds of mail fraud, a l l in

vio la t ion

of Ti t l e 18, United

Sta tes

Code, Section

1341, and

commercial bribery in v io la t ion of Section 39 of Chapter 271 of

the

Massachusetts

General

Laws.

All

in v io la t ion of

Ti t l e 18, United

Sta tes

Code,

Sect ions

1956 h and

1956

(a) (1)

i .

33




OUNT SIX

(Carpenter

#2

Extor t ion)

62. s se t for th

above

in paragraph 40, which i s

r es ta ted

here in

and

incorporated by

reference ,

from in or about

a t

l eas t

2009

and

continuing

un t i l

in or

about December 2010, within the

Dis t r i c t

of

Massachusetts ,

EDW RD J . MACKENZIE

JR.

defendant

herein, did

obstruc t

delay, and af fec t commerce

and

the

movement of

a r t i c l e s and

commodities in commerce by extor t ion

as

those

terms

are

defined

in

Ti t l e

18,

United

Sta tes

Code,

sec t ion

1951,

tha t

i s

MACKENZIE

obtained property,

to

wit ,

Uni

ted

Sta tes currency, from Carpenter

#2 with

Carpenter #2'

s

consent, which consent was induced

by

the wrongful use of actual

and

threatene d force, v iolence, and

fear .

All

in v io la t ion of Ti t l e

18,

United

Sta tes

Code,

Sect ion

1951.

4




COUNTS SEVEN ND

EIGHT

(Boiler Replacement

Job Wire

Fraud)

63. As se t for th above in paragraph 42, which i s res ta ted

here in

and incorporated

by

reference , from

a t

l e a s t

in

or about

December

2010,

to a t l e a s t in or about

October/November

2011,

MACKENZIE

devised and intended

to

devise the above-described

scheme and a r t i f i c e to

defraud

the Church, and to obtain

money

and proper ty by

means

of

mater ia l ly fa lse and f raudulent

pretenses, representa t ions and promises.

64.

On or

about each

of the dates

se t for th

below,

in

the

Dis t r ic t

of Massachusetts

and

elsewhere,

EDW RD J . MACKENZIE

JR. defendant

herein ,

aided and abet ted

by

others ,

known

and

unknown to the Grand Jury, for

the purpose

of execut ing the

scheme and

a r t i f i c e

described

above,

caused

to be t ransmi t ted by

means of

wire communication in in te r s ta te

commerce the

writ ings,

s ignals and sounds described

below:

COUNT DESCRIPTION

8

12/20/2010

12/20/2010

a.m.

p.m.

E-mail

E-mail

from

from

CPC

CPC

to BVC

to BVC

All

in

v io la t ion

of Ti t le 18, United Sta tes

Code,

Sect ions

1343

and 2 a) .

35




OUNTS NINE THROUGH THIRTEEN

(Booster Pump Job Wire Fraud)

65. As se t for th

above in

paragraph 47, which i s re s ta ted

herein

and incorporated by

reference , from

a t l e a s t in or

about

July

2011,

to a t l eas t

in or

about August 2011, MACKENZIE

devised and intended to devise the above -descr ibed

scheme and

a r t i f i c e to

defraud

the

Church, and

to obta in money

and

proper ty

by

means of mater i a l ly fa l se

and

f raudulent pre tenses ,

representa t ions

and promises .

66.

On

or about

each

of

the dates

se t for th below, in

the

Dis t r ic t of

Massachuset ts

and elsewhere, EDWARD J . MACKENZIE

JR.

defendant herein ,

aided

and

abet ted

by others , known and


Jury,

for the purpose of execut ing

the

scheme

and a r t i f i c e descr ibed above, caused to

be

t ransmit ted

by

means of

wire

communication

in

in te r s ta te commerce the

wri t ings ,

s ignals and sounds descr ibed below:

OUNT

DESCRIPTION

9

7/12/2011 E-mail from P

to Church

10 8/4/2011

E-mail

from

P to

Church

11 8/4/2011

E-mail

from P to MACKENZIE

12

8/10/2011 E-mail

from

Church

to

P

3

8/10/2011

E-mail from P to

Church

All

in v io la t ion

of

Ti t l e

18,

United

Sta tes

Code,

Sect ions

1343

and 2 a) .

36




COUNT FOURTEEN

Painter

#1 Wire Fraud)

67.

As

se t for th

above

in paragraph 52,

which i s

res ta ted

herein

and

incorpora ted

by

reference ,

from a t

l e a s t

in

o r

about

May 2009,

to

a t l e a s t on

or

about October

2009,

MACKENZIE

devised and in tended to devise the above-described

scheme

and

a r t i f i c e

to defraud

the Church, and to obta in money and proper ty

by means

of

mater i a l ly fa l se

and

f raudulent pretenses ,


promises .

68. On

o r

about

September

1,

2009, in the Dis t r ic t of

Massachusetts

and elsewhere, defendant EDWARD J MACKENZIE JR.,

defendant

herein ,

aided and abet ted

by

others , known and unknown

to the Grand Jury, for

the

purpose of execut ing the

scheme

and

a r t i f i c e

descr ibed above, caused to be

t ransmi t ted

by means

of

wire

communication

in i n t e r s t a t e commerce the following wri t ing ,

s ignal

and sound,

to wit, an

e-mail

from MACKENZIE to Pain ter

#1.

All

in v io la t ion

of Ti t l e

18,

United

Sta tes

Code,

Sect ions

1343 and

2 (a)

37




R CKETEERING

FORFEITURE

LLEG TIONS

18 U.S.C. §

1963

The Grand Jury fur the r charges that :

69.

Upon

convic t ion of

one

o r

more

of the offenses

in

v io la t ion of 18 U.S.C. §

1962

as

charged in Counts

One

and Two

of

t h i s

Indictment,

EDWARD

J. MACKENZIE JR. defendant herein,

sha l l fo r fe i t

to the United

Sta tes

of

America

pursuant to 18

U.S.C.

§

1963 (a) :

a. a l l

i n t e r e s t s

the

defendant has

acquired

and

maintained

in v io la t ion of

18

U.S.C. § 1962,

wherever located, and in

whatever names

held;

b.

a l l in te res t s

in secur i t i es

of, claims agains t and

proper t ies

and cont rac tua l

r igh t s

of any kind

afford ing

a

source of in f luence over, any ente rpr i se

which the defendant has

establ i shed

operated,

cont ro l led

conducted,

and par t i c ipa ted in

the

conduct

of in vio la t ion of

18 U.S.C.

§

1962; and

c.

a l l proper ty cons t i tu t ing and

derived from,

any

proceeds which the defendant obta ined, di rec t ly and

ind i rec t ly

from

racke teer ing

ac t iv i ty

and

unlawful

debt col lec t ion in vio la t ion of

18

U.S.C. § 1962.

70. The proper ty to

be for fe i t ed includes, but

i s

not

l imi ted to

the

sum of approximately

$1

mill ion

which

represents

the

proceeds of such vio la t ions .

71. I f

any

of the proper ty descr ibed in paragraph

69

hereof

as

being

for fe i t ab le

pursuant

to

18

U.S.C.

§

1963,

as

a

resu l t of any ac t

and

omission of the

defendant -

a. cannot be

loca ted upon the exerc ise of due

di l igencei

38




b. h as b ee n t r ans fe r red to so ld to

o r deposi ted

with

a th i rd party ;

c.

has been

placed

beyond

the j u r i sd i c t i on

of t h i s

Courti

d. has been

subs tan t i a l ly

diminished in value; or

e.

h as b een commingled with o ther proper ty

which cannot

be divided without di f f icu l tYi

t i s the in ten t ion of the United Sta tes pursuant to 18 U.S.C.

§

1963

(m), to seek

for fe i tu re

of any o ther proper ty of the

defendant

up to the value o f th e

proper ty

descr ibed in

paragraph

69 above, i n cl u di n g b u t n o t l imi ted to the following:

•

the r ea l

proper ty located

a t 955 Pleasant St ree t

Unit 1, Weymouth Massachusetts , inc luding a l l

bui ld ings

and appurtenances

thereon, more

par t i cu l a r l y descr ibed in a deed recorded

a t

Book

24132, Page 189 a t

the Norfolk County Regis t ry of

Deeds.

All pursuant to Ti t l e 18,

United Sta tes

Code, Sect ion 1963.

39




FR UD

ND EXTORTION

FORFEITURE ALLEGATIONS

18 U.S.C. § 981

and 28

U.S.C. § 2461

The Grand

Jury fur the r

charges tha t :

72.

Upon convic t ion

of one

or

more of

the of fenses in

v io la t ion of 18 U. S. C. §§ 1343,

1349

and 1951, as

charged

in

Counts

Three,

Four, and Six through

Fourteen of t h i s Indic tment ,

EDWARD J.

MACKENZIE

JR. defendant herein sha l l

fo r f e i t

to the

United Sta tes of

America

pursuant to 18 U.S.C. § 981(a)

(1) C)

and

28 U.S.C. § 2461(c),

any

proper ty , rea l

or

persona l , which

cons t i tu te s

or

i s

der ived

from

proceeds

t raceable

to

such

vio la t ions .

73.

I f any of the proper ty descr ibed in

paragraph

72

hereof as

being

for fe i t ab le

pursuant

to

18 U.S.C. § 981(a) (1)

C)

and 28 U.S.C. § 2461(c), as a r e su l t

of

any

ac t and omission of

the defendant

-

a . cannot

be

located upon the

exerc ise

of due

di l igence;

b. has been

t r ans fe r red

to so ld t o o r deposi ted with

a

t h i rd party ;

c.

has been

placed beyond

the

j u r i sd i c t i on

of

t h i s

Court;

d.

has

been s ubs t a n t i a l l y

diminished

in value; or

e .

has been commingled with other proper ty

which

cannot

be divided

without

d i f f i cu l ty ;

t i s the

in ten t ion

of the United

Sta tes

pursuant to 28 U.S.C.

§ 2461(c), to

seek for fe i tu re

of

any other

proper ty of the

40




defendant up to the value of the property described

in

paragraph

72

above, including but not l imi ted to the following:

•

the rea l

proper ty located

a t 955

Pleasant

s t ree t

Unit

1,

Weymouth

Massachusetts ,

including

a l l

bui ld ings

and appurtenances thereon,

more

par t i cu l a r l y descr ibed in a deed recorded a t Book

24132, Page 189 a t

the

Norfolk County Registry of

Deeds.

All pursuant

to Ti t le 18, United

Sta tes

Code, Sect ion

981

and

Ti t le 28, United

Sta tes

Code,

Section 2461.

41




MONEY

L UNDERING

FORFEITURE ALLEGATIONS

18 U.S.C. §

982

The

Grand

Jury fu r the r charges tha t :

74.

Upon

convic t ion

of the

offense in

v i o l a t i o n of 18

U.S.C. § 1956,

as

charged in Count Five of t h i s Indic tment ,

EDW RD

J .

MACKENZIE JR. ,

defendant

here in , sha l l

fo r f e i t to the

United Sta tes o f America pursuant to 18

U.S.C. §

982(a) ( I ) ,

any

proper ty , r e a l o r persona l , involved in such offense ,

and any

proper ty

t r aceab le

to such proper ty .

75. I f any

of

the proper ty descr ibed

in

paragraph

74

hereof as being

fo r f e i t a b l e pursuant

to

18 U.S.C. §

982(a) (1),

as a r e s u l t of

any

ac t

and

omiss ion of the defendant -

a .

cannot be

loca ted upon

the exerc i se of due

d i l igence :

b.

has been t r a n s fe r r e d

to ,

so ld t o , o r depos i t ed

with

a

t h i rd

par ty ;

c . has

been

placed beyond

the

j u r i s d i c t i o n of

t h i s

Court ;

d. has

been s ubs t a n t i a l l y

diminished

in value; o r

e . has been commingled with o ther prope r ty which cannot

be

divided

without d i f f i cu l tYi

t i s

the

i n t en t ion

of the United

Sta tes , pursuant

to 18 U.S.C.

§

982(b,

to

seek

fo r f e i t u r e

o f

any

o ther prope r ty

of

the

defendant

up to

the

value o f the prope r ty

descr ibed in

paragraph

74 above,

inc luding

but not l imi ted

to the

fol lowing:

42




•

the rea l

prope r ty located a t

955 Pleasant

St ree t

Unit I Weymouth Massachuset ts ,

inc luding a l l

bui ld ings and appur tenances

thereon,

more

pa r t i c u l a r ly

descr ibed

in a deed recorded a t Book

24132, Page 189 a t

the

Norfolk County

Regis t ry of

Deeds.

All

pursuant to

Ti t l e

18, un i ted Sta tes

Code, Sec t ion

982.

43




A TRU BILL

FORE PERSON OF THE

GRAND

JURY

TORNEY

DISTRICT

OF MASSACHUSETTS; May __2_\___ , 2013.

Returned

i n to

the

Dis t r i c t

Court by the Grand Jurors and

f i l ed

I

j

1 PIC-

(

r; cl l

/3

44


































Church on The Hill (Swedenborgian) The Boston Society of the New Jerusalem, Inc.140 Bowdoin Street ~ Beacon Hill ~ Boston, MA 02108 ~ www.churchonthehillboston.org

April 20Vol. VIII, Issue

!"#$# #&'( )*+," -+ ,". &// 0+$ 12+ &3" 1"&30 &4( 5$3("4

&4( 6 1'// 7'8" 0+$ 3"#-9 :&;" ,0 0+;" $<+4 0+$ &4( /"&34

=3+, ,". =+3 6 &, 7"4-/" &4( 2$,5/" '4 2"&3-. &4( 0+$ 1'//

>4( 3"#- =+3 0+$3 #+$/#9 ?+3 ,0 0+;" '# "&#0 &4( ,0 5$3("4

/'72-9) @&A2"1 BBCDE

Spring is here ! ! !

http://www.churchonthehillboston.org/




NEWSLETTER OF THE BOSTON CHURCH OF THE NEW JERUSALEM

2

GOALS AND OUR LIFE AS A CHURCH

! Seeking to be guided by love of God, love of others, being in community, seeking to be of service.! Church services and classes being vital and central.! Nurturing teamwork and community throughout the church.! The church welcoming diversity of people working together as one.! Developing a pervasive spirit of caring in the church community.! The church developing as welcoming of all generations (from children to senior).! Concerted efforts to involve young people more fully in the life of the church. Perhaps with aid from adults,

having leadership emerge from young people. Involvement of young people in service projects in thecommunity.

! Strengthening of programs for seniors, drawing on resources both within and outside the church.! Developing processes for ministry preparation.! Growth of participation from the congregation in the church activities.

MinistersRev. Dr. J. Ted Klein, Senior Pastor

Executive OfficialsMary Guarino, Presiden tDiane Williams, Vice President Robert von Wolfgang, Chairman of the Board of Trustees Susanne Rogers, Treasurer Michael Bancewicz, Secretary

DirectorsEdward J. Mackenzie, Jr., Director of Operations

Emeritus OfficialsMichael Latkowitch, President Emeritus

Anna Hunt Latkowitch, Church Council Emeritus

MusicCarlton Doctor, Minister of Music

Victor Cayres de Mendonca, Organist and Pianist

Michael Bancewicz, Acting Editor Craig Williams, Assistant Editor

New Jerusalem ChurchCirca 1845

The foundation of the Boston Society of the New Jerusalem(BSNJ) can be traced back to 1784 and the Green DragonTavern in Boston. It was then and there that admirers of, andthose interested in learning more about, EmanuelSwedenborg first met to hear a lecture on Swedenborg by

James Glen. In 1818, twelve people, some of whom wereamong the early “Green Dragon Tavern crowd,” organized aSwedenborgian Church in the city. Chartered in 1823, theBoston Society of the New Jerusalem, Inc. is the firstSwedenborgian Church established in Massachusetts.

Members of the Church met at several locations beforefinally settling in 1845 at its present location atop BeaconHill. The location inspired the name by which many todayknow the society: the Church on the Hill (Swedenborgian).Through the years, noted BSNJ members include TimothyHarrington Carter, publisher, and founder of the Old CornerBook Store; Sampson Reed, writer and mentor of RalphWaldo Emerson; Lydia Maria Child, author, social activistand abolitionist; Warren Felt Evans, writer and healer;

HISTORY OF THE CHURCH

Theophilus Parsons, dean of Harvard Law School; OtisClapp, apothecary, publisher, member of the MassachusettsHouse of Representatives, co-founder of The MassachusettsInstitute of Technology (M.I.T.), Boston University, and andfounder of The Home for Little Wanderers; Theophilus P.Chandler, architect; Clarence Barron, financier, editor of theWall Street Journal, and president of Dow Jones; George

James Webb, hymnologist; and The Honorable MalcolmNichols, Mayor of Boston. A beautiful Gothic Revivalstructure served the membership until the 1960s when it wasreplaced with a new Church building and an eighteen storyhigh- rise apartment. Today, the main sanctuary of the

Church is accessible from Bowdoin Street. The Church hasalso served as a place of worship and gatherings for the localMuslim Community and other faith-based communities. TheChurch has organizes and runs many programs to meet theneeds of the Church community and larger surroundingneighborhood.

Use of the Church facility is offered to human service andoutreach organizations.



CHURCH ON THE HILL - ESTABLISHED 1818

3

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NOTICE FROM THE SENIOR PASTOR

Rev. Dr. Ted Klein

Please pray for the people of Japan and all others inneed!

The congregation collections for April and May will bedonated as follows:

April collections will go for relief of the people of Japan.

May collections will go to the Walk For Hunger.

The Oasis Coalition of Boston in collaboration with

Suffolk University's S.O.U.L.'s Program have organized a

health fair featuring many service providers and health

organizations around the city of Boston.

The Fair will be open to all women with a special

emphasis to our newly housed, poor and homeless.

There will be gift packages available for attendees that

will include toiletries etc...

Food and snacks will be provided by the Suffolk Students

Please, Please spread the word!

Women’s Health Fair

Friday April 8th

12 Noon until 5:00 PM




4

Walk For HungerMay 1, 2011

The Walk for Hunger is an annual tradition and a rite

of spring in Massachusetts! Join 40,000 caring friends

and neighbors and raise money for those struggling to

make ends meet. Since 1969, The Walk for Hunger

has been a tradition in Massachusetts. Today, the

Walk has become the country's oldest continual

pledge walk and the largest one-day fundraiser to

alleviate local hunger. On the first Sunday in May

each year, more than 40,000 Walkers and 2,000

Volunteers

start off from the Boston Common

tomake a difference in the lives of our neighbors. In

Massachusetts, more than 660,000 people do not have

enough food to eat. The Walk for Hunger raises

millions of dollars for the 400 emergency food

programs that support families in crisis. The Walk is still looking for volunteers, whether

you want to walk, hand out supplies, or work the finish line, the more help the better!

Our own Mike Bancewicz, Maria McKenzie, and Donald

Gonzalez will be walking this year. Also, Rob Day and

Donnie MacDougall will be working at the finish line. To

join team Church on the Hill as a volunteer or walker,

call the Church. The Walk for Hunger is a nationally

respected event where all proceeds go towards making

sure that no one goes hungry.

Every donation and volunteer effort goes a long way and

we hope that you can help make a difference!

For More information, including how to donate and sign up to volunteer, visit

www.projectbread.org or www.churchonthehillboston.org

http://www.projectbread.org/


http://www.projectbread.org/site/PageServer?pagename=help_fundedagencies_list













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Roland Mills received his B.M. in Vocal

Performance from Northern Arizona University. He

is a tenor studying classical voice with Dr. Rebecca

Folsom, and currently attends the Boston

Conservatory of Music seeking a Masters Degree.

He currently holds a position in the music history

department of the same school working as a

teachers’ assistant, and maintains a voice studio at

the Boston Arts Academy. His recent performancesinclude leading roles in Britten's The Rape of

Lucretia, Die Zauberflöte, and Gianni Schicchi,

which he performed in Italy. His future Aspirations

include performing on the greatest of operatic

stages, teaching voice at the college level, and

establishing a school of music in Trinidad, the

country of his birth.

Meet The Choir...Some Thoughts on

Resurrection

Late in April we will be celebratingEaster. In our tradition we think ofEaster and the resurrection of Jesus.What are resurrections in our lives?How does the resurrection of Jesusrelate to our lives?

In the rebirths of spring, the break outof new life, we can see kinds of

resurrection. Life continues, new lifeemerges.

According to our beliefs each of us, atdeath, continues on in a new life. Weare risen and continue as spiritualbeings, with a chance to grow moreand more fully into the person we canbe.

We can approach Jesus as continuallywith us as we face challenges and findnew life in this world. In that wayresurrection can happen over and overagain in our lives.

God, help raise us from darkness tolight, from coldness to warmth, from

fear to freedom, from self concern tolove and caring. Amen.

Rev. Dr. Ted KleinSenior Pastor

Roland Mills




9

From the Editor

Greetings!March was

an eventful monthand April/May lookto be even moredynamic. We willbe hosting aWomen!s Health fair(see page 3). A Jack and Jill Baby Shower (page 10)Guest Minister Marion Easterling (page 10) Walk forHunger (page 4) and of course the arrival of our long

awaited Steinway piano plus much more. On any givenday the church is buzzing with some kind activity, thoughsome times distracting, it is evident that we are blessedwith success in building the mission of the church!Please see the calendar on page 15 for events of theEaster Season.

A contingency from the church attended CMM!s 45Annual Meeting and Awards Dinner. Speaking of CMM,they are awarding us their first VolunteerismAchievement Award! On March 20th we had our fourth

“Laity in the Pulpit” this one being led by EddieMackenzie with participation from many others. Themusic, message and inter-activeness made this one verymemorable. Being out of town I was sorry to havemissed Rev. Manikka!s message celebrating Women!sHistory Month, but I have heard that the message wasstrong and well received.

Congratulations to Mary Guarino for being the winner oflast months “Can you name who!s who” contest havingbeen able to name 11 of the 12 photos. She will receive

a $50 gift card to Scollay Square Restaurant. We arehaving another contest this month (page 11) and thewinner who guesses the most will win a gift card to the21st Amendment. Call Craig or me at the office or mailin your answers, Good luck!

Blessings,Mike

Our New Piano!

The Church will be receiving ournewly refurbished SteinwayPiano on Thursday, March 31. Weare very excited to hear how thesound will enhance our growing SundayServices along with our upcomingSpring Concert, which will be held atthe Church on May 15. Mike, Carlton,and Victor travelled to New York City topersonally see and hear the piano andwere very pleased and excited withwhat they heard. It is a 100 year oldpiano which was refurbished, by hand,and completely redone to make it

visually stunning as well as upping thesound quality. Victor is ecstatic to finallybe able to put this piano to use duringthe Church Service on Sunday, April 3.




10

Correspondence

A Jack and Jill baby shower will be held at the

Church on the Hill for Felicia Vega, who hasapplied for Church Membership, on April 10 at1PM. Church Members are invited to makethis a specialday!

On Sunday, April 10, we will have a SpecialGuest Minister, Rev. Marion Easterling. Marion isthe Senior Pastor at Old West Church onCambridge Street in Boston. He has served as apastor in Albuquerque, New Mexico andColorado Springs, Colorado. In his currentappointment, he is serving Old West Church,United Methodist of Boston, Massachusetts.

Baby Shower




11

Guess Who?Congratulations to Mary Guarino for winning last month.

She guessed 11 out of 12. Tied for second were Terry Mazzulli and Anne Klein

with 10 out of 12. The answers were from left to right and top to bottom;

Rosie the Riveter, Rosa Parks,Mother Teresa, Eleanor Roosevelt,Helen Keller, Harriet Tubman, Maya

Anjelou, Indira Gandi, Golda Meir,Rachel Revere, Sacagawea, EdithPiaf. April!s winner will get a $50 giftcard to the 21st Amendment.

SWEDENBORG READING New Life in People and in Nature

“… when people are being reborn, spiritual life flows into them, just as when a tree is budding, its life

flows in by heat from the sun. One who is born a person is in the Word throughout compared to beings in the

vegetable kingdom, especially trees; and this is because the whole vegetable kingdom, as well as the animal

kingdom, represents such things as are in people. (Arcana Coelestia, no. 5115)




12

A little boy came up to his mother in the kitchen one evening while she was fixing

supper, and handed her a piece of paper that he had been writing on. After his Momdried her hands on an apron, she read it, and this is what it said:

For cutting the grass: $5.00

For cleaning up my room this week: $1.00

For going to the store for you: $.50

Baby-sitting my kid brother while you went

shopping: $.25

Taking out the garbage: $1.00

For getting a good report card: $5.00

For cleaning up and raking the yard: $2.00Total owed: $14.75

Well, his mother looked at him standing there,

and the boy could see the memories flashing

through her mind. She picked up the pen,

turned over the paper he'd written on, and this

is what she wrote:

For the nine months I carried you while you were growing inside me:

No ChargeFor all the nights that I've sat up with you, doctored and prayed for you:

No Charge

For all the trying times, and all the tears that you've caused through the years:

No Charge

For all the nights that were filled with dread, and for the worries I knew were ahead:

No Charge

For the toys, food, clothes, and even wiping your nose:

No Charge

Son, when you add it up, the cost of my love is:No Charge.

When the boy finished reading what his mother had written, there were big tears in

his eyes, and he looked straight at his mother and said, "Mom, I sure do love you."

And then he took the pen and in great big letters he wrote: "PAID IN FULL".

Simple Acts of Kindness...

http://www.inspireme.net/inspirational-stories/mothers_love.htm
















13

Oasis Book Club meets with Author Lara

Bricker after reading her book Lie After

Lie.

On March 8th we had the pleasure of invitingLara Bricker, the author of our last reading

selection, to the group for a Q&A session.

Lara is a freelance writer currently residing in

Exeter, New Hampshire. This selection was

suggested by Michael Bancewicz, an

acquaintance of Lara. Lie After Lie: the true

story of a master of deception, betrayal, and

murder is a true crime story detailing the

murder of thirty-one year Julie Keown. Her

story book marriage to husband James Keown

took a horrific turn when James began

poisoning Julie with anti-freeze disguised in

Gator-Aide bottles. Her subsequent death

resulted in an investigation that began in

Waltham, Massachusetts and ended in

Missouri from where the couple originated.It’s a chilling story and a great read.

Our current reading selection is Mystic River

penned by Boston native Dennis Lehane. We

are in the promising process of inviting Mr.

Lehane sometime in May to discuss his book,

too.

The Oasis Coalition of Boston wishes to extend

an invitation welcoming all those interested in

attending the book club. Again, we meet each

and every Tuesday at 10:am. Books are

provided by Oasis at no cost to attendees.

Coffee and doughnuts are provided as well.

The Oasis book club is eternally grateful to the

Church on the Hill, Senior Pastor Rev. Dr. Ted

Klein, Director of Operations Edward J.

Mackenzie Jr. and Administrator Michael

Bancewicz for their combined hospitality, not

only for the book club but for all the Oasis

programs housed here at 140 Bowdoin Street.

The Oasis Coalition of Boston book club is

hosted by Church on the Hill each Tuesday

between the hours of 10 AM and 12 PM.

Rob Day

Her storybook marriage to husband

James Keown took a horrific turn when ...

from the book “Lie After Lie”

Ned Carlton, Lara Bricker and Rob Day




14

The Streets Are Ours!

The Oasis Coalition of Boston!s Board ofDirectors.

Donnie MacDougall, Rob Day, Dr. Debra Harkins David Fisher, Chair and Michael Bancewicz. Notseen in the photo is newly appointed TreasurerSusanne Rogers.

Mike preparing braciole.

Boston Youth Organizing Project meet at Church on the Hill before lobbying at the State House.

Rev. Manikka Bowman was our GuestLeader on March 20 for Women!s HistoMonth.

A weekly screenwriting class that meets in the Church everyWednesday 4-6 PM. The class is run by Megan Rice, astudent at Emerson College.




15

Church Calendar Events 2011All are welcome. Come as you are.

April

Sunday, April 3 9:45 AM Swedenborg Class with Rev. Dr. Ted Klein

11:00 AM Church Service with Rev. Dr. Ted Klein

Wednesday, April 6 5:00 PM Church Council Meeting

6:00 PM Board of Trustees Meeting

Sunday, April 10 9:45 AM Bible Reflection

11:00 AM Church Service with Rev. Marion Easterling

Sunday, April 17 9:45 AM Palm Sunday. Swedenborg Class with Rev. Dr. Ted Klein


Wednesday, April 20 12:00 Noon Senior Lunch

Thursday, April 21 6:00 PM Maundy Service and Communion with Rev. Dr. Ted Klein

Sunday, April 24 11:00 AM Easter. Easter Service with Rev. Dr. Ted Klein

MaySunday, May 1 9:45 AM Bible Reflection

11:00 AM Church Service and Communion with Rev. Dr. Ted Klein

Wednesday, May 4 5:00 PM Church Council Meeting

6:00 PM Board of Trustees Meeting

Sunday, May 8 9:45 AM Swedenborg Class with Rev. Dr. Ted Klein

11:00 AM Mothers Day. Church Service with Rev. Dr. Ted Klein

Sunday, May 15 9:45 AM Bible Reflection

11:00 AM Spring Choir Concert

Wednesday, May 18 12:00 Noon Senior Lunch

Sunday, May 22 9:45 AM Swedenborg Class with Rev. Dr. Ted Klein

11:00 AM Church Service with Dr. Mary Kay Klein

Sunday, May 29 9:45 AM Bible Reflection




Church on The Hill (Swedenborgian)

The Boston Society of the New Jerusalem, Inc.

140 Bowdoin Street, Beacon Hill

Boston, MA 02108-2799

Check Out The New Website at www.churchonthehillboston.org

Documents

Steve Ellis - Ted Klein - Edward MacKenzie - 02-27-2015.pdf