approves: A“ ST eluaed ais Gupra NOAH SOLOWIEJCZYK/EDWARD B. DISKANT/ROBERT BOONE/ RUSSELL CAPONE Assistant United States Attorneys Before: THE HONORABLE JAMES L. COTT United States Magistrate Judge Southern District of New York 1 my MAG "1 1 8 d UNITED STATES OF AMERICA SEALED COMPLAINT Violations of 18 U.S.C. 58 371, 666, LAMONT EVANS, 1343, 1346, 1349, EMANUEL RICHARDSON, : and 2 a/k/a “Book, “ ANTHONY BLAND, a/k/a Tony, * CHRISTIAN DAWKINS, and MUNISH SoOD, COUNTY OF OFFENSE: NEW YORK Defendants. : pte 2a2 ae mio a 8 SOUTHERN DISTRICT OF NEW YORK, ss.: JOHN VOURDERIS, being duly sworn, deposes and says that he is a Special agent with the Federal Bureau of Investigation ("FBI"), and charges as follows: COUNT ONE (Conspiracy to Commit Bribery) 1. From at least in or about 2016, up to and including in or about September 2017, in the Southern District of New York and elsewhere, LAMONT EVANS, EMANUEL RICHARDSON, a/k/a “Book,” ANTHONY BLAND, a/k/a “Tony,” CHRISTIAN DAWKINS, and MUNISH SOOD, the defendants, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit offenses against the United States, to wit, violations of Title 18, United States Code, Sections 666 (a) (1) (B) and 666(a) (2).2, Tt was a part and object of the conspiracy that LAMONT EVANS, EMANUEL RICHARDSON, a/k/a “Book,” and ANTHONY BLAND, a/k/a “Tony,” the defendants, being agents of organizations that received, in a one-year period, benefits in excess of $10,000 under a Federal program involving a grant, contract, subsidy loan, guarantee, insurance, and other form of Federal assistance, to wit, University-2, University-3, University-4 and University-5,+ corruptly would and did solicit and demand for the benefit of a person, and accept and agree to accept, something of value from, among others, CHRISTIAN DAWKINS and MUNISH SOOD, the defendants, and a cooperating witness for the Government (“CW-1") and undercover law enforcement officers intending to be influenced and rewarded in connection with a business, transaction, and series of transactions of such organizations, involving something of value of $5,000 and more in violation of Title 18, United States Code, Section 666 (a) (1) (B) 3. Tt was further a part and an object of the conspiracy that CHRISTIAN DAWKINS and MUNISH SOOD, the defendants, and others known and unknown, corruptly would and did give, offer. and agree to give something of value to a person, with intent to 2 In addition to the bribery and fraud scheme described herein the investigation has revealed additional instances of bribe payments to coaches at NCAA Division I universities, as well as a related scheme involving significant cash payments by athlete advisors, and executives of at least one athletic apparel company, to the families of high-school student-athletes, at the vequest of basketball coaches at two NCAA Division I universities, in exchange for agreements by those athletes to attend the universities and later to sign with the advisors and apparel company who made the bribes. These additional schemes are detailed in two related Complaints also unsealed today. see United States v. Chuck Connors Person, et al., 17 Mag. » and United States v. James Gatto, et al., 17 Mag. . For ease of reference in reading and understanding the three related Complaints, together all universities and players referenced in this Complaint and the two related Complaints have been numbered sequentially, without duplicating defined terms, beginning with University-1 and Player-1 in United States v. Chuck Connors Person, et alinfluence and reward an agent of an organization, in connection with business, transactions, and series of transactions of such organization involving a thing of value of $5,000 and more, while such organization was in receipt of, in any one year period, benefits in excess of $10,000 under a Federal program involving a grant, contract, subsidy, loan, guarantee, insurance, and other form of Federal assistance, in violation of Title 18, United States Code, Section 666(a) (2). OVERT ACTS 4, In furtherance of the conspiracy and to effect the illegal objects thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. On or about March 3, 2016, in South Carolina, LAMONT EVANS, CHRISTIAN DAWKINS, MUNISH SOOD, the defendants, and CW-1 met, during which meeting EVANS, DAWKINS, SOOD and cW-1 discussed, in sum and substance and in part, that EVANS could direct and influence certain student-athletes that EVANS coached at University-2 to retain the services of DAWKINS, SOOD and cW- os b. On or about April 19, 2016, EVANS met with CW-1 and SO0D in Manhattan, New York, during which meeting CW-1 provided EVANS with a cash bribe of $500. ©. On or about February 3, 2017, EVANS met with CW-1 in West Virginia, during which meeting CW-1 provided EVANS with a cash bribe of $2,000 and EVANS introduced CW-1 to a basketball player at University-3. d. On or about June 20, 2017, SOOD, EMANUEL RICHARDSON, a/k/a “Book,” the defendant, CW-1, and an undercover FBI agent (*UC-1"), among others, met in Manhattan, New York, during which meeting RICHARDSON received a cash bribe of $5,000. e. On or about July 20, 2017, SOOD, RICHARDSON, and UC-1 met in New Jersey, during which meeting RICHARDSON received a cash bribe of $15,000.