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GEORGEMOSES,
Defenda*
CRIMINAL COMPLAINT
I, the complainant in ttis case, state tiat the following is true to the best of my knowledge and belief
On or about the dates of July 25,2018 and July 31,2018, in the County of Morroe, in the Westem District
ofNew York, the defendant violated Title 18 U.S.C. $ 1001, said offenses described as follows:
There is probable cause to beteve that the defendant, GEORGE MOSES, did knowingly violate Title 18, United
States Code, Section 1001, by making false statements to Special Agents ofthe FBI.
Cotrplaiflail\ sigruture
Daniel A. Ciavarri, Special Agent,
Federal Bureau of Investigation
Pinted n@?re ond title
INTRODUCTION
been so employed for over 7 years. I have been trained to investigate, and have participated
in investigations o{ a wide range of federal crimhal violations, including fraud and public
comrption. I am empowered by law to conduct investigations of, and make arrests for,
false statements to Special Agents of the FBI. The false statements were rnade in a mattel
within the jurisdiction of the executive branch of the Govemment of the United States.
investigation in this case, including witress interviews and reviews of records, my experience
and background as an FBI Special Agent, and information provided by other law enforcement
officers engaged in the investigation. Because I am submitting this affidavit for the limited
purpose of securing a criminal complaint, I have not set forth eadr and every known fact
lmown to me relating to this investigation. Rather, I have set forth only those facts that I
believe are recessary to establish probable cause to believe that GEORGE H. MOSES did
BACKGROI]ND
4. MOSES resides in Rochester, New York and is the chairman of the Board of
Commissioners of the Rochester Housing Authority ("RIIA) and a board member of the
Rochester Housing Charities ('RHC). He was the chairperson of the board of the RHC
and services for the Rochester community. It oversees approximately 2,500 public-housing
units, millions of dollars and subsidies for tens of thousands of people. The RHA has an
affrual contract with the United States Deparnnent of Housing and Urban Development from
6. The RHC is located in Rochester, New York. On or about March 20, 2013,
the RIIA formed the RIIC to assist in advancing the purposes of the RIIA. On or about
February 12,2014, the Intemal Revenue Sewice granted RHC tax exempt status as a not for
profit entity.
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Washington, D.C. Firm - Carital Connection Partners LLC
T.]hza:.3,CapitalCorrnectionParbrersLLCC.CCP)wasformedasalimited
liability company in Washington, D.C. Its alleged mission was to plovide premier business
and consulting services to govemment entities and organizations wishing to conduct business
involving Washington, D.C. and the Fedelal govelnment. CCP is now deftmct and i6
only
client was the RHC. Lisa Ransom was one of the three partnels that made up CCP,
which
8. From on or about octobel 14, 2014, to on or about December 20, 2014' Adam
McFadden was the Interim Executive Director of the RHA. On or about January 23 , 2015 '
Conkacts
g. on or about July 7 , 2015, the RHC enteled into an $87,500 oDe year contract
wift ccP (,the RHC and CCP Contract"), which provided that CCP would perform various
services for the RHC, including (a) advocating at the local, state and federal level of
govemment for policy and legislation, reviewing best practices, and issuing presentations to
elected officials, and (b) finding self sufficient resources to include creating entrepleneurial
opportunities and workforce development, developing revenue streams for residents, and
Development LLC, executed a conEact with CCP entitled tire Pass Through Funding ald
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Services Agreement (the "McFadden Pass Through Agreement"), which provided that CCP
would pass ttrrough 75% of the funds it received from the RHC to Caesar Development LLC.
FAISE STATEMENTS
11 . On July 25 , 2078, Special Agents of the FBI, including your affiaat, intervievred
MOSES at the RHA regarding the RHC and CCP Contract and the McFadden Pass Through
Agreement. During that interview, MOSES made the following false statements:
(a) When asked how RHC leamed of CCP, Moses stated he could
not recall specifically who brought CCP to the attention of the
RHC.
12. On July 31, 2018, Special Agents ofthe FBI, including your afEant, interviewed
MOSES at the United States Attomey's Office in Rochester regarding the RHC and CCP
Conrract and the McFadden Pass Through Agreement. During that interview, MOSES made
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the following false statements:
(a) When told that McrFadden and his company received money
from the Rt{C and CCP Contract, Moses stated that he was
surprised that McFadden and Caesar Development LLC
received such money.
(b) When discussing a meeting held between CCP and the boards of
the RHA and RHC on December ll , 2075 , Moses stated that he
was surprised that McFadden was also at the meeting.
13. The evidence discussed below establishes that when he was interviewed by
PROBABLE CAUSE
14. During the time that McFadden was Interim Director of the RHA, MOSES was
the Chairperson of the Board of Commissioners of the RHA. While Interim Dfuector,
McFadden advised MOSES that McFadden wanted to get the RHC up and runaing.
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15. In early January 2015, McFadden contacted Lisa Ransom at CCP to discuss CCP
entering into a contract with the RHC. McFadden and Ransom had been prior
acquaintances. At this time, MOSES did not have a prior relationship with anyone of the
16. Between on or about January I , 2015 , and March 25, 2015 , MOSES engaged in
Board of Commissioners (a) to appoint him as one of the three new board members of the
RHC, and (b) to approve a loan by the RHA to the RIIC in the amount of $300,000. At ttris
time, the RIIC only consisted of tfuee board members, and had no employees or executive
staff.
18, On or about May ll, 2015, MOSES had at least two telephooe calls with
McFadden, presumably to discuss approving the hiring of CCP by the RHC at the RHC board
19 . On or about May 12, 2015, at the RHC board meering, MOSES and the other
two board members agreed that RIIC would hire CCP to perform various services for the
RHC. MOSES knew at the time that the RHC had not received a formal bid for the contract
from CCP nor from any other company because no company ever provided a forrnal bid.
20. One of the other two RHC board members stated that MOSES introtluced and
suggested the hiring of CCP to the other two RHC board members. The otler two board
members had not known of CCP until MOSES advised them of CCP. Thus, because MOSES
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had no prior knowledge of nor relationship with CCP, and because the other two board
members fust leamed of CCP from MOSES, there is probable cause to believe that MOSES
first leamed of CCP from McFadden and then brought CCP to the attention of the other two
board members. By bringing CCP to the attention of the other two board members, MOSES
21. On or about May 27, 2015, MOSES had two telephone calls with McFadden,
during which it b reasonable to assume that they discussed the RHC and CCP Contract and
22. On or about May 28, 2015, at approximately ll:.42 a.m., McFadden emailed
MOSES drafts of the RHC and CCP Contract and the McFadden Pass Through Agreement.
As stated above, the McFadden Pass Through Agreement provided that McFadden's
company, Caesar Development LLC, would be receiving 7 5o/o of the money the RHC would
be paying to CCP under the terms of the RHC and CCP Contract.
23. Between on or about May 28, 2015, the day MOSES received the drafts of the
two contracts, and July 6, 2018, the day before the RHC and CCP Contract was executed by
the RHC, MOSES had almost daily telephone calls with McFadden.
24. On or about July 7,2015, the RHC executed the RHC and CCP Contract. At
that time, MOSES knew that CCP would be payng 7 5o/o of the money it received from the
involvement in the RHC and CCP Connact ftom both boards of the RHC and the R[IA.
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25. On or about July 8, 2105, McFadden, on behalf of his company, Caesar
Development LLC, executed the McFadden Pass Through Agreement. MOSES and
26. On or about August 3, 2015, although the RHC and CCP Contract had only
been entered into less than a month earlier, the RHA on behalf of the RHC paid CCP $43,750,
which represented the first installment payment under the terms of the RHC and CCP
Contract. At this time, MOSES was board chairperson of the RIIA and a board member of
theRHC.
LLC, which represented 7 5% of ttre funds CCP had just received from the RHA.
28. On or about h:try 22,2015, MOSES and aoother RHC and RHA board
member, submitted to the RIIA board of commissioners a copy of fraudulent RHC board
minutes from the May 12,2015, RHC board meeting. The board minutes falsely stated the
RHC had received three formal bids before selecting CCP as the low bidder. The board
minutes also failed to identiff McFadden's company, Caesar Development LLC, nor state
that Caesar Development LLC would be receiving most of the funtls from the RHC and CCP
Contract.
29. On or about December 10, 2015, two members of CCP traveled to Rochester
and met with McFadden and MOSES at a local restaurant. Prior to that meeting, MOSES
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30. On or about December 11,2015, the two members of CCP along with
McFatltlen attended a meeting with the RHC and RHA board members at a hotel in
Rochester. There is probable cause to believe that MOSES knew that McFadden would be
attending this meeting and that he was not surprised to see McFadden at the meeting.
31. Prior to the RHC's second $43,750 payment to CCP by the RHC in December
2015, McFadden regularly spoke with MosES and sent him emails during and in which they
discussed the second installrnent payment by the RHC to CCP. MOSES tnew that
McFadden's company, Caesar Development LLC, wogld be receiving funds from t}is second
payment.
32. On or about December 23, 2015, the RHC paid $43,750 to CCP, which
represented the second installrnent payment undel the terms of the RIIC and CCP Contract.
At this time, MOSES was board chairperson of the RIIA and a board member of the RHC.
. 33. OnoraboutDecerfierz4,20l5,CCPpaid$32,812-50toCaesarDevelopment
LLC, which rep resented 7 5o/o of the funtls CCP had just received from the R[IC.
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CONCLUSION
34. Based on the foregoing, I respecfrrlly submit that there is probable cause to
believe that GEORGE MOSES did lnowingly violate Title 18, United States Code, Section
?* f, /,---
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Daniel A. Ciavarri, Special Agent
Federal Bureau of Investigation
rY1uiu.i?^,rr-.
HON. MARIAN W. PAYSON
United States Magrstrate Judge
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