The Case Against Jefferson D-La (United States Of America v. William J. Jefferson, Defendant)

In The United States District Court
For The Eastern District of Virginia
Alexandria Division

CRIMINAL NO. 1:07CR209
• Count 1: 18 V.S.C. & 371 (Conspiracy to Solicit Bribes by a Public Official, Deprive Citizens of Honest Services by Wire Fraud, and Violate the Foreign Corrupt Practices Act)
• Count 2: 18 V.S.C. & 371 (Conspiracy to Solicit Bribes by a Public Official and Deprive Citizens of Honest Services by Wire Fraud)
• Counts 3-4: 18 V.S.C. & 201(b)(2)(A) (Solicitation of Bribes by a Public Official)
• Counts 5-10: 18 V.S.C. && 1343 and 1346 (Scheme to Deprive Citizens of Honest Services by Wire Fraud)
• Count 11: IS V.S.C. & 78dd-2(a) (Foreign Corrupt Practices Act)
• Counts 12-14: 18 V.S.C. & 1957 (Money Laundering)
• Count 15: 18 V.S.c. & 1512(c)(I) (Obstruction of Justice)
• Count 16: 18 V.S.C. & 1962(c) (Racketeer Influenced Corrupt Organization, Pattern of Racketeering Activity (RICO» Forfeiture Allegations: 18 V.S.C. && 981, 982, and 1963; 28 V.S.C. & 2461

Indictment
June 2007 Term - At Alexandria
The Grand Jury Charges That:

General Allegations
At all times relevant to this Indictment:
Since 1991, WILLIAM J. JEFFERSON, the defendant, was a Member of the United States House of Representatives, representing the 2" Congressional District in the State of Louisiana. As such, he was a public official within the meaning of Title 18, United States Code, & 201(a)(I).
2. Defendant JEFFERSON maintained several offices for the purpose of conducting his official congressional duties, including offices in Washington, D.C., and New Orleans, Louisiana. Defendant JEFFERSON supervised and directed the activities of congressional staff membcrs who worked in those offices and who, at the direction of Defendant JEFFERSON, routinely contacted government agencies on behalf of constituents.
3. At various times relevant to this Indictment, Defendant JEFFERSON was a Member of the Committee on Ways and Means, Subcommittee on Trade; Member of the Committee on the Budget; Co-Chair of the Africa Trade and Investment Caucus; and Co-Chair of the Congressional Caucus on Nigeria.
4. Defendant JEFFERSON received a Juris Doctor degree from Harvard University in Junc 1972 as well as a Master of Laws Degree in Taxation from the Georgetown University Law Center in February 1996. In addition, Defendant JEFFERSON was a citizen of the United States, and as such, Defendant JEFFERSON was a "domestic concern" within the meaning of the Foreign Conupt Practices Act of 1977 ("FCPA"), 15 U.S.C. & 78dd-2(h)(1)(A).
The Congress of the United States and Responsibilities of Members of the United States House of Representatives
5. The Congress of the United States, comprised of a Senate and House of Representatives, was established by Article I of the United States Constitution. Since that time, Members of Congress have played an important role in the system of government in the United States by proposing and passing laws, taking actions to protect citizens, and providing services and assistance to their constituents.
6. At the beginning of a new Congress, each Member was required to take the following oath of office: I, (Member's Name), do solemnly swear (or affirm) that I will support and defend the Constitution of the United States against all enemies, foreign and domestic; that I will bear true faith and alJegiance to the same; that I take this obligation 1Teely, without any mental reservation or purpose of evasion; and that I will well and faithfully discharge the duties of the office on which I am about to enter: So help me God.
7. In addition to the above-referenced oath, the Rules of the United States House of Representatives set forth certain rules and codes of conduct that: a. prohibited a Member of the House from receiving outside acompensation as a result of the improper exercise of influence from the Member's position in Congress;
b. prohibited a Member of the House from earning outside income in a calendar year that exceeded 15% of a certain basic pay rate;
c. required that a Member of the House file Annual Financial Disclosure Statements with the Clerk of the House; 8.
d. required that a Member of the House seek an exemption from the House Committee on Standards of Official Conduct to receive more than $250 worth of gifts annually, and, in any event, only from a person the Member designated as a personal friend;
e. prohibited trips by a Member of the House paid for by private sources unless the trip was taken in connection with the Member's duties as an officeholder; and
f. required that a Member of the House and the Member's staff sign and file a Travel Disclosure Form ("Travel Form") with the Clerk of the House within 30 days after any trip paid for by private sources, with the Travel Form containing detailed information about the purpose, cost, and sponsor of the trip, and an affirmation that the travel was in connection with the Member's duties as an officeholder and would not create the appearance that the Member was using public office for private gain.
Consistent with his oath of office and the duties of the office he held, Defendant JEFFERSON owed the citizens of the United States and the United States House of Representatives a duty to perform the responsibilities of his office free from deceit, fraud, concealment, bias, conflict of interest, self-enrichment, and self-dealing.

Relevant Individuals
9. Vernon L. Jackson ("Jackson"): Since in or about January 1998, Jackson was the president, chief executive officer, and chairman of the board ofiGate, Incorporated, a Louisville, Kentucky telecommunications firm.
10.Brett M. Pfeffer ("Pfeffer"): In 2004 and 2005, Pfeffer was employed as the president of an investment firm located in Mclean, Virginia. In the mid-1990's, Pfeffer served on the congressional staff of Defendant JEFFERSON in both his New Orleans and Washington, D.C.,.offices. In addition, Pfeffer was a citizen of the United States, and as such, was a "domestic concern" within the meaning of the FCP A, 15 U.S.C. 9 78dd-2(h)(1 )(A).
11. Nigerian Official A: In 2004 and 2005, Nigerian Official A was a high-ranking official in the executive branch of the Government of the Federal Republic of Nigeria and acted in an official capacity for and on behalf of the Federal Republic of Nigeria, and as such, was a "foreign official" within the meaning of the FCPA, IS U.S.C. ~ .78dd-2(h)(2)(A). During this same time period, a spouse of Nigerian Official A ("Nigerian Official A's Spousc"), who lived in Potomac, Maryland, was a United States citizen, and as such, was a "domestic concern" within the meaning of the FCPA, 15 U.S.C. 78dd-2(h)(I)(A).
12. Cooperating Witness ("CW"): In or about March 2005, a McLean, Virginia, businessperson reported a suspected fraud involving iGate, Jackson, and Defendant JEFFERSON to the Federal Bureau of Investigation ("FBf'). After contacting the FBI, that businessperson becamc a cooperating witness for the government.
13. Jefferson Familv Members: Certain relatives of Defendant JEFFERSON, by birth or by marriage, are referred to in this Indictment as "Family Members 1-5," respectively.
14. Congressional Staff Members: Individuals employed by the Office of Congressman WILLIAM J. JEFFERSON, are referred to in this Indictment as "congressional staffmembers." Relev3_nt United States Government Agencies
15. Export-import Bank of tbe United States ("Ex-Im Bank"): The Ex-Im Bank, with its headquarters in Washington, D.C., was the official export credit agency of the United States and was established by Congress as an agency of the United States "to aid in financing and to facilitate exports and imports and the exchange of commodities and services between the United States. . . and any foreign country or the agencics or nationals thereof." The Ex-Im Bank typically provided loan guarantees and other means of financing designed to support United States exports to foreign countries.
16. United States Trade and Development Agency ("USTDA "): The USTDA, with its headquarters in Arlington, Virginia, within the Eastern District of Virginia, was established by Congress as an agency of the United States "to promote United States private sector participation in development projects in developing and middle-income countries, with special emphasis on economic sectors with significant United States export potential, such as energy, transportation, telecommunications, and environment." The USTDA pursued this goal by funding vatious fonns of technical assistance, investment analysis, training, orientation visits, and business workshops. Jefferson Family-Controlled Companies Defendant JEFFERSON participated in controlling and directing the actions of each of the following companies:
17. The ANJ Grono. L.L.C. ("ANJ"): ANJ was a limited liability company organized under the laws of the State of Louisiana on or about January 19, 2001. Records on tile with the Louisiana Secretary of State listed Family Member 1 as an organizer, manager, and member of ANJ. Five other Jefferson family members were also listed as members of ANJ, and Defendant JEFFERSON's accountant and campaign treasurer was listed as the registered agent for ANJ.
18. B.E.P. Consulting Services. LLC ("BEP"): BEP was a limited liability company organized under the laws of the State of Louisiana on or about October 24, 2000. Records on file with the Louisiana Secretary of State listed Family Member 2 as a registered agent, member, and president of BEP.
19. Global Energy & Environmental Services LLC ("Global"): Global was a limited liability company organized under the laws of the State of Delaware on or about March 21,2003, and, as such. was a "domestic concern" and Defendant JEFFERSON was an "agent of such domestic concern" within the meaning of the FCP A, 15 U.S.C. && 78dd-2(a) and 18dd 2(h)(1)(B). Company records listed five Jefferson faruily members as members of Global.
20. Intemational Petroleum LLC ("International Petroleum"): International Petroleum was a limited liability company organized under the laws of the State of Louisiana on or about May 24, 2002. Records on file with the Louisiana Secretary of State listed the daughter of a congressional staff member as the manager, organizer, and registered agent of International Petroleum.
21. Jefferson Interests. Inc. ("Jefferson Interests"): Jefferson Interests was incorporated under the laws of the State of Louisiana on or about January 3, 1983, and whose authority to do business in Louisiana was revoked on or about November 19, 1990. Records on file with the Louisiana Secretary of State listed Defendant JEFFERSON as the president, Faruily Member 2 as the secretary and treasurer, and another Jefferson family member as the vicepresident of the corporation.
22. Multi-Media Broad Band Senrices.. Inc. ("Multi-Media"): Multi-Media was incorporated under the laws of the State of Delaware on or about July 20,2005, by Defendant JEFFERSON. Defendant JEFFERSON designated Faruily Member 5 as the chief executive officer of Multi-Media. As of August 3, 2005, ANJ held a 40% ownership interest in Multi-Media.
23. Providence International I'droleum Company. LLC ("PIPCO"): PIPCO was a limited liability company organized under the laws of the State of Louisiana on or about January 29, 2002. Records on file with the Louisiana Secretary of State listed a congressional staff member as the organizer and manager of PIPCO. Those records also listed Defendant JEFFERSON's accountant and campaign treasurer as the registered agent of PIP CO.
24. Providence Lake. L.L.C. ("Providence Lake"): Providence Lake was a limited liability company formed on August 25, 2000, and organized under the laws of the State of Louisiana on or about October 5, 2000, and it also did business as "Providence International Company" and "Providence International, LLC." Records on file with the Louisiana Secretary of State listed a congressional staff member as the organizer and manager of Providence Lake.
Those records also listed Defendant JEFFERSON's accountant and campaign treasurer as thc registered agent of Providence Lake.

Companies That Defendant JEFFERSON solicited for Bribes
25. iGate. Incorporated ("iGate"): iGate was incorporated undcr the laws of the State of Indiana in or about January 1998 and headquartered in Louisville, Kentucky. As such, iGate was a "domestic concern" and Defendant JEFFERSON was an "agent of such domestic concern" within the meaning of the FCPA., 15 V.S.C. 99 78dd-2(a) and 78dd-2(h)(I)(B). Vernon L. Jackson was tbe president, chief executive officer, and cbairman of the board of iGate. iGate developed and marketed "Triple Play" technology, which enabled audio, video, and data to be transmi tied over copper wire.
26. W2-ffiBS. Limited ("W2-IBBS”): W2-IBBS was a company organized under the laws of the Federal Republic of Nigeria. W2IBBS was controlled by CW.
27. International Broad Band Services. LLC (“IBBS”): IBBS was a company that was in the process of being registered under the laws of the Republic of Ghana. IBBS was controlled by CW.
28. Nigerian Company A: Nigerian Company A was a telecommunications company with its corporate offices located in Abuja, Nigeria. Nigerian Businessperson A was involved in conducting its operations.
29. Companv A: Company A was a business that provided satellite-based radio and data broadcasting services to subscribers in numerous regions of the world. Company A was headquartered in Washington, D.C. Company A's chairman and chief executive officer was a person hereinafter referred to as Businessperson A.
30. Company 8: Company B was a South African business that, among other things, sought certain drilling rights to deep water oil reserves located in the territorial waters off the coast of the Republic of Sao Tome and Principe in the Gulf of Guinea. Company B was represented by a person hereinafter referred to as Businessperson BC. A person hereinafter referred to as Lobbyist A was involved with these deep water oil reserves.
31. Comnanv C: Company C was incorporated under the laws of the State of Delaware that manufactured and sold systems that convened various traditional waste products into electricity for commercial and residential use. Company C was represented by Businessperson BC.
32. Company D: Company D was incorporated under the laws of the State of Louisiana whose business was to provide full service design, engineering, and construction services in nwnerous regions of the world, including Africa. A person hereinafter referred to as Businessperson DEF was vice-president of Company D and participated in decisions concerning the direction and control of Company D.
33. Company E: Company E was a corporation organized under the laws of the State of Louisiana whose business was to provide services related to the design and construction of sugar factories. Businessperson DEF participated in decisions concerning the direction and control of Company E.
34. Company F: Company F was a corporation organized under the laws of the State of Louisiana whose business was, in part, to develop oil and natural gas projects internationally. Businessperson DEF participated in directing and controlling Company F.
35. Company G: Company G was a limited liability company organized under the laws of the State of Louisiana whose business objectives included the development of various projects in Nigeria such as marginal oil fields and a fertilizer plant. A person hereinafter referred to as Businessperson G was a member of Company G and participated in directing and controlling Company G. Lobbyist A also represented Company G in connection with its efforts to gain the official assistance of Defendant JEFFERSON. Other Nigerian Businesses
36. Nigerian Comnany B: Nigerian Company B was an Internet service provider with its headquarters in Abuja, Nigeria. Nigerian Businessperson B was the founder and chief executive officer ofNigeria,," Company B.
37. Nigeria Telecommunications. Ltd. ("NlTEL"): NlTEL was a governmentcontrolled Nigerian company headquartered in Nigeria., and was the main telecommunications service provider in Nigeria.
38. Nigerian Joint Venture: From in or about August 2004 through August 2005, Defendant JEFFERSON, CW, Nigerian Businessperson B, and others negotiated a joint venture agreement between W2-IBBS and Nigerian Company B to pursue a telecommunications business in Nigeria using iGate technology and equipment The proposed joint venture ("Nigerian Joint Venture") contemplated a partnership between W2-IBBS and Nigerian Company B wherein costs and profits would be divided between them with W2-IBBS maintaining a controlling interest in the Nigerian Joint Venture.

COUNT 1
Conspiracy to Solicit Bribes by a Public Official, Deprive Citizens of Honest Services by Wire Fraud, and Violate the Foreign Corrupt Practices Act THE GRAND JURY FURTHER CHARGES THAT:
39. Paragraphs I through 38 of this Indicttnent are re-alleged as if fully set forth herein.

THE CONSPIRACY AND ITS Objects
40. Beginning in or about January 2001 through in or about August 2005, within the Eastern District of Virginia and elsewhere, the defendant, WILLIAM J. JEFFERSON, did knowingly combine, conspire, confederate, and agree, together with Vernon L. Jackson, Brett M. Pfeffer, and others known and unknown to the grand jury, to commit the following offel1S1:S against the United States:
a. to, directly and indirectly, corruptly demand, seek, receive, accept, and agree to receive and accept anything of value personally and for any other person and entity, in return for being influenced in the perfonnance of any official act, in violation of Title 18, United States Code, Section 201(b)(2)(A);
b. to devise a scheme and artifice to deftaud and deprive the citizens of the United States and the United States House of Representatives of their right to the honest services of Defendant JEFFERSON, performed free from deceit, fraud, concealment, bias, conflict of interest, self-enrichment, and self-dealing, and to use wire communications in interstate and foreign commerce to further the scheme to deftaud, in violation of Title 18, United States Code, Sections 1343 and 1346; and
c. to willfully use the mails and any means and instrumentalities of interstate commerce corruptly in furtherance of an offer, payment, promise to pay, and authorization of the payment of any money, and offer, gift, promise to give, and authorization of the giving of anything of value to any foreign officials for purposes of: (i) influencing acts and decisions of such foreign officials in their official capacities; (ii) inducing such foreign officials to do and omit to do acts in violation of the lawful duty of such officials; (iii) securing any improper advantage; and (iv) inducing such foreign officials to use their influence with a foreign government and instrumentality thereof to affect and influence any act and decision of such government and instrumentality, in order to assist Defendant JEFFERSON and others in obtaining and retaining business for and with, and directing business to, any person, in violation of Title 15, United States Code, Section 78dd-2(a).

NATURE AND PURPOSE OF THE CONSPIRACY
The nature and purpose of the conspiracy included the following:
41. To provide for the unjust enrichment of Defendant JEFFERSON and his family members by corruptly seeking, soliciting, and directing that things of value be paid to him and his family members in rcturn for Defendant JEFFERSON's performance of official acts.
42. To use the Office of Congressman WILLIAM J. JEFFERSON, including the congressional staff members employed therein, to perform official acts to advance the interests of the businesses and persons who had agreed to pay things of value to Defendant JEFFERSON and his family members.
43.To conceal the illegal nature of Defendant JEFFERSON's solicitations for, and receipt of, various things of the value through the preparations of misleading written agreements, the use of nominee companies, and the omission of material facts concerning the financial benefits that were sought on behalf of, and received by, Defendant JEFFERSON and his family members, all to ensure the continued existence and success of the conspiracy.
44. To offer, promise, and make bribe payments to foreign officials of the Federal Republic of Nigeria, including Nigerian Official A, in order to advance the business interests of the Nigerian Joint Venture, its members and stockholders, and others who had agreed to pay Defendant JEFFERSON and his family things of value in return for his official acts.

MANNER AND MEANS OF THE CONSPIRACY
Among the manner and means by which Defendant JEFFERSON and his co-conspirators would and did carry out the conspiracy were the following:
45. As a Member of the United States House of Representatives and certain of its committees and caucuses, Defendant JEFFERSON discussed providing official assistance to constituent companies, including iGate and CW's companies, and businesspersons, including Vernon Jackson and CW, seeking to obtain and conduct business in west African nations, including Nigeria, Ghana, and Cameroon.
46. After initially discussing such business endeavors with these businesspersons, Defendant JEFFERSON sought things of value for himself and his family mcmbers in return for providing official assistance to promote those business endeavors. The things of value Defendant JEFFERSON sought in return for providing his official assistance included monthly fees or retainers, consulting fees, percentage shares of revenue and profit, flat fees per item sold, and stock ownership in thc companies seeking his official assistance.
47. Defendant JEFFERSON sought to and did conceal his and his family members' expected or actual receipt of things of value by directing congressional staff members, family members, and others to form nominee companies that entered into business agreements to receive the things of value sought by Defendant JEFFERSON while not referencing him or disclosing his involvement in obtaining the agreements. The nominee companies included ANJ, Global, and Multi-Media.
48. While seeking things of value, Defendant JEFFERSON typically required that the agreements with the nominee companies be reduced to writing to make them appear to be lawful agreements for professional and legitimate services when, in fact, the companies and businesspersons were giving things of value to Defendant JEFFERSON and his designees in return for official acts to be performed by Defendant JEFFERSON.
49. In return for things of value, Defendant JEFFERSON agreed to perform and did perform a pattern of official acts to promote and advance the business interests of these companies and businesspersons in West Afiica and elsewhere. These official acts included:
a. conducting official travel to foreign countries and meeting with foreign government officials for the purpose of influencing those officials;
b. using his congressional staff members to create trip itineraries, accompany Defendant JEFFERSON on travel, and otherwise provide official assistance;
c. contacting both United States and foreign embassies to schedule meetings with foreign government officials, obtaining entry and exit visas for travelers, and otherwise assisting with the official travel;
d. sending official cOITeSpondence on congressional letterhead to foreign government officials; and
e. scheduling and participating in meetings with officials of United States agencies to secure potential financing for the business ventures sought by the companies and businesspersons.
50. Defendant JEFFERSON failed to disclose his and his family's financial interests in these business ventures by omitting this material information from travel and financial disclosure forms required to be filed by the Rules of the United States House of Representatives and, in some cases, by simply failing to make any of the required filings.
51. Defendant JEFFERSON failed to disclose to United States and foreign government officials his and his family's financial interests in the business ventures he was officially promoting in order to give the false impression that Defendant JEFFERSON was merely acting as an impartial public servant promoting United States business interests abroad.
52. Defendant JEFFERSON, Nigerian Businessperson B, and others agreed that bribes would be paid, as needed, to various Nigerian government officials if deemed necessary to the success of the Nigerian Joint Venture. Defendant JEFFERSON was responsible for negotiating, offering, and delivering the payment of bribes to Nigerian Official A to induce Nigerian Official A to use his position to assist in securing approvals necessary to the success of the Nigerian Joint Venture. Nigerian Businessperson B was responsible for the payment of bribes to lower ranking Nigerian government officials to ensure the success of the Nigerian Joint Venture.

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OYERT Acr.S
In furtherance of the conspiracy, and to effect the objects thereof, the following overt acts were committed within the Eastern District of Virginia and elsewhere: Defendant JEFFERSON Soul"ht Bn"bes from iGate for ANJ
53. In or about January 2001, after initially assisting iGate, Defendant JEFFERSON informed Jackson that Defendant JEFFERSON would not continue to use his official position as a United States Congressman to promote iGate's business unless Jackson agreed to pay ANJ (a Jefferson family-controlled company).
54. In or about January 2001, Defendant JEFFERSON presented a "Professional Services Agreement" to Jackson that called for payments from iGate to ANJ, including monthly payments of$7,5oo.oo; 5% ofiGate's gross sales and certain capital raised; and options for up to one million shares of iGate stock over a five-year period.
55. On or about January 15,2001, Jackson signed the Professional Services Agreement on behalf of iGate and Family Member I signed on behalf of ANJ.
56. On or about January 19,2001, Defendant JEFFERSON and Family Member I caused the formation of ANJ under the laws of the State of Louisiana.
57. On or about January 22, 2001, Jackson caused iGate to issue 100,000 shares of iGate stock to ANJ.
58. On or about February 15,2001, Jackson caused the first of several payments of $7,500.00 to be made to ANJ.
59. In or about June 2002, Defendant JEFFERSON introduced Jackson 10 a Member of the United States House of Representatives, who was a prominent member of the -17- Subcommittee on Telecommunications, Trade, and Consumer Protection, for the purpose of garnering that Member's support for iGatc's technology without disclosing Defendant JEFFERSON's family's financial interest in iGatc's business.
60. On or about October 22, 2002, as a result of the above-referenced meeting, Defendant JEFFERSON caused the aforementioned Member to send to iGate on official congressional letterhead and under that Member's signature praising iGate's technology. Defendant JEFFERSON Sought Bribes from Nigerian Company A
61. In or about July 2003, in Nigeria, Defendant JEFFERSON met executives of Nigerian Company A, who were pursuing a telecommunications venture in Nigeria and elsewhere in Africa, and advised them that iGate could provide the goods and services desired by Nigerian Company A.
62. On or about July 20, 2003, in London, England, Defendant JEFFERSON introduced Jackson to Nigerian Company A executives, including Nigerian Businessperson A, who preliminarily agreed to purchase iGate's products and services for Nigerian Company A's use in Nigeria.
63. On or about July 20, 2003, in London, England, without Jackson's knowledge, Defendant JEFFERSON solicited from Nigerian Businessperson A a percentage of revenue and stock, as well as fees estimated to be worth $1 million, to be paid to Defendant JEFFERSON, all in return for Defendant JEFFERSON's official assistance with Nigerian and United States government officials to further a telecommunications venture by Nigerian Company A and iGate in Nigeria.

Defendant JEFFERSON Sougbt an Increase in Bribe Pavments from iGate for ANJ
64. On or about July 24,2003, in Washington, D.C., Defendant JEFFERSON presented Jackson witb an "Amendment to Professional Services Agreement," which required iGate to pay ANJ 35% of any profits derived from iGate's business in Africa.
65. On or about August 6, 2003, in New York, New York, Jackson, on behalf of iGate, entered into a business agreement whereby Nigerian Company A agreed to pay iGate a total of $44,934,400.00 contingent upon an iGate production schedule, which included a $6.5 million up-front payment to iGate by Nigerian Company A within five business days of entering into tbe agreement.
66. In or about August 2003, in Washington, D.C., Defendant JEFFERSON introduced Jackson and Nigerian Company A executives to personnel oftbe Ex-1m Bank for tbe purpose of obtaining financial support for iGate and Nigerian Company A's venture in Nigeria.
67. On or about September 22, 2003, after iGate had received approximately $1.5 million pursuant to its business agreement witb Nigerian Company A, Defendant JEFFERSON caused Family Member I to submit an invoice to Jackson seeking $240,000.00 "currendy due to [ANJ] as compensation under its professional services agreement."
68. On or about December 27, 2003, in anticipation of additional payments from Nigerian Company A to iGate, Defendant JEFFERSON reminded Jackson in writing that iGate owed money to ANJ, stating, "When tbe money comes in in a few days for the African project, I trust that . . . iGate's debt to ANJ will be brought fully current. It now stands at $262,500.00." -19-
69. On or aboul January 23,2004, one day after iGate had received approximately $5 million from Nigerian Company A, Jackson caused $200,000.00 to be wired from iGate's bank account in New Albany, Indiana, to ANJ's bank accounl in New Orleans, Louisiana.
70. On or about January 26, 2004, Jackson caused an additional $30,000.00 to be wired from iGale's bank account in New Albany, Indiana, 10 ANJ's bank account in New Orleans, Louisiana.
71. On or about January 28, 2004, Defendant JEFFERSON presented a memorandum 10 Jackson proposing thai iGate issue additional shares of iGate slock: 10 ANJ, increasing ANJ's ownership stake in iGate 10 15%.
72. On or about February 2, 2004, Defendant JEFFERSON caused a congressional staff member 10 send an e-mail from Defendant JEFFERSON's Washington, D.C., congressional office to the United States Embassy in Abuja, Nigeria, seeking assistance in arranging meetings for Defendanl JEFFERSON with high-ranking Nigerian government officials during Defendant JEFFERSON's upcoming trip 10 Nigeria.
73. On or about February 15, 2004, Defendant JEFFERSON, Jackson, a congressional staff member, and others departed from Washington Dulles International Airport in Loudoun County, Virginia, on an iGate co-sponsored trip 10 several west African nalions, including Nigeria, to promote iGate and other business ventures 10 government officials of those nations.
74. From on or about February 17, 2004, through on or about February 20,2004, Defendant JEFFERSON, in his capacity as a Member of the United Stales House of Representatives, met with government officials in Nigeria and Cameroon and promoted iGale -20-

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