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Case 2:16-cr-00502-AM Document 3 Filed 04/13/16 Page 1 of 6

SEALED
,J1\T1TED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
DEL RIO DIVISION

UNITED STATES OF AMERICA

;) :3

INDICTMENT

v.

HECTOR CHAVEZ, SR.

VIOLATIONS: COUNT ONE: 18 U.S.C.


666(a)(2), Paying a Bribe to an Agent of an
Organization Receiving Federal Funds;
COUNT TWO: 18 U.S.C. 1519,
Falsification of Records in a Federal
Investigation; COUNT THREE: 18 U.S.C.
151 2(c)(2), Obstruction of Justice, COUNT
FOUR: 18 U.S.C. 1001, False Statement or
Representation.

DRI6CRO5O2
THE GRAND JURY CHARGES:

At All Times Material To This Indictment:


1.

CONTRACTOR A was a principal at FIRM A, a corporate firm providing

engineering and planning services.


2.

Maverick County, a political subdivision of the State of Texas, contracted with

FIRM A to provide services related to a number of large construction projects from 2006 through
2012.
3.

In order to secure those contracts from Maverick County, CONTRACTOR A

provided monetary and non-monetary benefits to Maverick County commissioners, elected


county officials, for the purpose of ensuring the commissioners would support the selection of
FIRM A to perform contracts for professional services and as a reward for the commissioners'

support after FIRM A was awarded such Maverick County contracts.

Case 2:16-cr-00502-AM Document 3 Filed 04/13/16 Page 2 of 6

4.

One such contract awarded to FIRM A related to the Maverick County landfill

project in Precinct 2 ("the landfill project").


5.

FIRM

A,

To secure this contract and to reward support for the awarding of this contract to

CONTRACTOR A paid monetary kickbacks to MAVERICK COUNTY

COMMISSIONER A ("COMMISSIONER A"). These kickbacks were paid by CONTRACTOR


A or through other individual(s) used by CONTRACTOR A to make the payment.
6.

HECTOR CHAVEZ, SR. ("CHAVEZ") owned and operated Chace Management.

7.

CONTRACTOR A, under the guise of sub-contracting with Chace Management

for services related to the landfill project, gave money to CHAVEZ for the purpose of CHAVEZ

providing a portion of that money to COMMISSIONER A as a kickback for the landfill project.
8.

On at least four (4) occasions in 2012, CHAVEZ provided kickbacks in the form

of cash payments of at least $5,000 each, or approximately $20,000 total, to COMMISSIONER


A on behalf of CONTRACTOR A for the landfill project.
9.

FIRM A received approximately $270,000 from Maverick County to perform

services related to the landfill project.


10.

In the one year period beginning on January 1, 2012, Maverick County, Texas

was a local government that received federal benefits in excess of $10,000 from the United

States Department of Homeland Security.


11.

Between on or about August 20, 2014 and on or about September 22, 2014,

CHAVEZ devised to create, and did in fact falsify and forge, a professional services contract
between CHAVEZ/Chace Management and CONTRACTOR A/FIRM A to conceal from
authorities the kickbacks made in the form of cash payments to COMMISSIONER A in 2012.

Case 2:16-cr-00502-AM Document 3 Filed 04/13/16 Page 3 of 6

12.

On or about May 4, 2015, a federal Grand Jury subpoena was issued to Chace

Management to provide "any and all records regarding any subcontracting or consulting work
done for, with, on behalf of, or in association with" FIRM A.
13.

In response to the federal Grand Jury subpoena, CHAVEZ provided the forged

and falsified professional services contract between Chace Management and FIRM A. CHAVEZ
represented in writing that such contract was a true record of the matters contained therein.
14.

On or about June 25, 2015, CHAVEZ made materially false oral representations

to two federal law enforcement agents concerning the legitimacy of the forged contract

CHAVEZ sent in response to the federal Grand Jury subpoena.

CflT IKIT ('1T1'

[18 U.S.C.

666(a)(2)]

Paragraphs One through Fourteen above are realleged and incorporated by reference as if
fully set forth herein.

Between on or about May 1, 2012 and on or about June 30, 2012, in the Western District

of Texas, Defendant,
HECTOR CHAVEZ, SR.
did corruptly give, offer, and agree to give a thing of value to MAVERICK COUNTY

COMMISSIONER A, an agent or employee of Maverick County, intending to influence and


reward MAVERICK COUNTY COMMISSIONER A in connection with a transaction and series

of transactions of Maverick County involving $5,000 or more, in violation of Title 18, United
States Code, Section 666(a)(2).

Case 2:16-cr-00502-AM Document 3 Filed 04/13/16 Page 4 of 6

COUNT TWO
[18 U.S.C.

1519]

Paragraphs One through Fourteen above are realleged and incorporated by reference as if
fUlly set forth herein.

Between on or about August 1, 2014 and on or about June 30, 2015, in the Western
District of Texas, Defendant,
HECTOR CHAVEZ, SR.
did knowingly falsify a document with the intent to impede, obstruct, and influence the

investigation and proper administration of justice in relation to and in contemplation of a matter


within the jurisdiction of the Federal Bureau of Investigation, a department and agency of the
United States of America, in violation of Title 18, United States Code, Section 1519.

COUNT THREE
[18 U.S.C. 1512(c)(2)]
Paragraphs One through Fourteen above are realleged and incorporated by reference as if
fully set forth herein.
Between on or about August

1,

2014 and on or about June 30, 2015, in the Western

District of Texas, Defendant,


HECTOR CHAVEZ, SR.
did corruptly attempt to obstruct, influence, and impede an official proceeding of a federal Grand

Jury by forging a professional services contract and submitting such forged contract as true in

response to a federal Grand Jury subpoena, in violation of Title 18, United States Code, Section
15 12(c)(2).

ru

Case 2:16-cr-00502-AM Document 3 Filed 04/13/16 Page 5 of 6

COUNT FOUR
[18 U.S.C.

1001]

Paragraphs One through Fourteen above are realleged and incorporated by reference as if
fully set forth herein.
On or about June 25, 2015, in the Western District of Texas, Defendant,

HECTOR CHAVEZ, SR.


did

willfully

and knowingly make a materially false, fictitious, and fraudulent statement and

representation to a Special Agent of the Federal Bureau of Investigation concerning a


professional services contract with FIRM A, which concerned a matter within the jurisdiction of
the executive branch of the Government of the United States of America, in violation of Title 18,

United States Code, Section 1001.

A TRUE BILL.

PiREPERSO7
RICHARD L. DURBIN, JR.
United States Attorney

By:

/1
J'ATIE GRIFF
Assistant United States Attorney

Case 2:16-cr-00502-AM Document 3 Filed 04/13/16 Page 6 of 6

SEALED:
UNSEALED: XX

PERSONAL DATA SHEET


UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
DEL RIO DIVISION
USAO#: 2016R05646

COUNTY: MAVERICK

MAG. CT. #: MATTER

DATE: APRIL 13, 2016


AUSA: KATHERINE GRIFFIN

DEFENDANT: HECTOR CHAVEZ, SR.


CITIZENSHIP: UNKNOWN

INTERPRETER NEEDED: YES

LANGUAGE: ENGLISH

DEFENSE ATTORNEY: NOT APPOINTED YET


ADDRESS OF ATTORNEY:

DATE OF ARREST: NOT ARRESTED

DEFENDANT IS: NOT DETAINED


BENCH WARRANT NEEDED:

PROBATION OFFICER: N/A


NAME AND ADDRESS OF SURETY: N/A
YOUTH CORRECTIONS ACT APPLICABLE: NO
PROSECUTION BY: INDICTMENT

OFFENSE: (Code & Description): Count

1: 18

U.S.C.

of an Organization Receiviun Federal Funds; Count 2:


Records in a Federal Investigation; Count 3: 18 U.S.C.
Count 4: 18 U.S.C.

1001

666(a)(2)

Paying a Bribe to an Agent

18 U.S.C.

1512(c)(2)

1519

Falsification of

Obstruction of Justice;

False Statement or Representation.

OFFENSE IS: FELONY

MAXIMUM SENTENCE: Count

1:

0-10 years imprisonment, a $250,000 fine,

years of

supervised release, and a $100 special assessment; Counts 2 and 3: 0-20 years imprisonment, a
$250,000 fine,

years of supervised release, and a $100 special assessment; Count 4: 0-5 years

imprisonment, a $250,000 fine, 3 years of supervised release, and a $100 special assessment.

PENALTY IS MANDATORY: YES & NO


REMARKS: SEE ABOVE
W/DT-CR-3
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