UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Holding a Criminal Term
Grand Jury Sworn in on May 15, 2009
UNITED STATES OF AMERICA V. YITBAREK SYUME, BERHANE LEGHESE, and AMANUEL
GHIRMAZION, Defendants.
CRIMINAL NO. CR-09-254, UNDER SEAL
VIOLATION: 18 U.S.C. § 371 (Conspiracy to Commit Bribery);
18 U.S.C. §2 (Aiding and Abetting,
Causing an Act to be Done)
INDICTMENT
The Grand Jury charges that:
COUNT ONE
Introduction
1. The District of Columbia Taxicab Commission ("DCTC")
regulates the operation of taxicabs in Washington, D.C. The DCTC, among
other things, establishes criteria, standards, and requirements for
taxicab licensing, including the licensing of owners, operators,
companies, associations, and. fleets. It also sets licensing fees. The
DCTC comprises seven commissioners and a chairperson.
2. Public Official Number One became
chairperson of the DCTC on or about July 7, 2007. As part of his official duties, Public Official
Number One (the "Chairperson") performed the following acts
among others:
(a) the Chairperson had authority and
influence over the issuance of licenses to operate multi-vehicle taxicab
companies in the District of Columbia;
(b) the Chairperson had authority and influence over the
issuance of individual District of Columbia taxicab operator licenses
which, when issued, authorized individuals to operate taxicabs in the
District of Columbia;
(c) the Chairperson could recommend to
the Council of the District of Columbia and others legislation affecting
the taxicab industry in Washington, D.C.; and
(d) the Chairperson could present positions to the
Council of the District of Columbia and others in opposition to proposed
legislation affecting the taxicab industry in Washington, D.C.
3. Historically, taxicab fares in the District of
Columbia had been determined by a zone system, but, pursuant to
legislation, on or about October 17, 2007, the District of Columbia
adopted a meter system. It was widely anticipated in the taxicab
industry, based on the adoption of meter systems in other cities, that
the adoption of a meter system would lead to a more regulated taxicab
industry, including stringent limitations on the total number of
taxicabs licensed to do business in the District of Columbia.
4. On or about July 15, 2008, the
Council of the District of Columbia enacted a moratorium on the issuance
of multi-vehicle taxicab company licenses. Given this moratorium, the
DCTC may not issue any new taxicab company licenses, rendering
multi-vehicle taxicab company licenses a valuable commodity.
The Conspiracy
5. From between in or about September 2007, until in or
about September 2009, the exact dates being unknown to the grand jury,
in the District of Columbia and elsewhere, defendants YITBAREK SYUME
("SPUME"), BERHANE LEGHESE ("LEGHESE"), and AMANUEL
GHIRMAZION ("GHIRMAZION"), knowingly and willfully conspired
and agreed together and with each other, and with other persons both
known and unknown to the grand jury, to commit the following offenses
against the United States: that is to directly and indirectly, corruptly
give, offer, and promise things of value to the Chairperson, with intent
to influence official acts, that is, SYUME, LEGHESE, and GHIRMAZION
agreed to give approximately $220,000 in cash to the Chairperson in
return for the Chairperson's agreement to issue numerous multi-vehicle
taxicab company licenses, in violation of Title 18, United States Code,
Section 201(b) (Bribery of a Public Official).
A Goal of the Conspiracy
6. It was a goal of the conspiracy to
obtain corruptly licenses for multi-vehicle taxicab companies from the
Chairperson in exchange for cash and other things of value.
Manner and Means of the Conspiracy
7. SYUME, LEGHESE, GHIRMAZION (the
"DEFENDANTS"), and other unindicted co-conspirators, both
known and unknown to the Grand Jury, used the following manner and means
to accomplish a goal of the conspiracy:
(a) It was part of the conspiracy that the DEFENDANTS
would and did play different roles in the conspiracy, and took upon
themselves different tasks and participated in the conduct of the
organization through various criminal acts, The DEFENDANTS made
themselves and their services available at various times throughout the
life of the conspiracy and participated in activities required to obtain
corruptly licenses for multi-vehicle taxicab companies. Some of the
roles assumed and carried out by the DEFENDANTS and other unindicted
co-conspirators both known and unknown to the Grand Jury included,
included among others, collecting large sums of cash to be used for
bribe payments to the Chairperson. They agreed to pay the Chairperson
approximately $10,000 per license for multi-vehicle taxicab companies.
The principal role of GHIRMAZION was to raise money for the scheme; the
principal role of LEGHESE was to prepare documents associated with the
corruptly obtained multi-vehicle taxicab company licenses; and the
principal role of SYUME was to arrange for and make a series of bribe
payments to the Chairperson.
(b) It was further part of the conspiracy that attempts
were made to obtain corruptly large numbers of licenses for
multi-vehicle taxicab companies from the Chairperson.
(c) It was further part of the conspiracy that the
DEFENDANTS intended to sell some of the licenses for multi-vehicle
taxicab companies that they had corruptly obtained to finance their
scheme, and to hold the balance of the licenses in anticipation
of the licenses becoming more valuable.
(d) It was further part of the conspiracy that the
DEFENDANTS and unindicted co-conspirators used telephones to facilitate
their bribery scheme; that is, to communicate with each other and with
the Chairperson.
Overt Acts
8. In furtherance of the conspiracy and in order to
achieve the goals thereof, SYUME, LEGHESE, GHIRMAZION, and other
unindicted co-conspirators, both known and unknown to the Grand Jury,
within the District of Columbia, and elsewhere, committed overt acts,
including, but not limited to the following:
(1) On or about September 5, 2007, SYUME gave to the
Chairperson a list of seven multi-vehicle taxicab companies for which he
requested licensing without proper authorization.
(2) On or about September 5, 2007, SYUME
also gave to the Chairperson an envelope containing approximately
$14,000 in cash in exchange for the requested licenses.
(3) On or about September 6, 2007, SYUME gave two
envelopes containing a total of approximately $8,000 in cash to the
Chairperson in exchange for multi-vehicle taxicab company licenses.
(4) On or about September 25, 2007,
SYUME received from the Chairperson multivehicle taxicab company
licenses for which SYUME had previously paid.
(5) On or about October 1, 2007, SYUME gave the
Chairperson approximately $2,000 in cash as partial payment for the
multi-vehicle taxicab licenses that he had received to date.
(6) On or about October 2, 2007, SYUME gave the
Chairperson an envelope that contained approximately $2,000 in cash as
partial payment for multi-vehicle taxicab company licenses.
(7) On or about October 3, 2007, SYUME put a folded
newspaper containing approximately $3,000 in cash into the Chairperson's
automobile as partial payment for multi-vehicle taxicab company
licenses.
(8) On or about October 17, 2007, SYUME again put a
folded newspaper containing approximately $3,000 in cash into the
Chairperson's automobile as partial payment for multi-vehicle taxicab
company licenses.
(9) On or about November 3, 2007, SYUME and GHIRMAZION
spoke by telephone, at which time GHIRMAZION provided information for
use on a document that SYUME was preparing in relation to the
multi-vehicle taxicab company licenses that they were attempting to
obtain from the Chairperson.
(10) On or about November 8, 2007, SYUME and LEGHESE
spoke by telephone, at which time they discussed selling for $150,000
apiece the multi-vehicle taxicab company licenses that they were
attempting to obtain from the Chairperson.
(11) On or about November 14, 2007, SYUME gave a shopping
bag containing approximately $59,880 in cash to the Chairperson in
partial payment for ten multivehicle taxicab company licenses.
(12) On or about November 18, 2007, SYUME and LEGHESE
spoke by telephone, at which time they agreed to meet so that LEGHESE
could give to SYUME fraudulent paperwork related to the multi-vehicle
taxicab company licenses which they were attempting to obtain from the
Chairperson.
(13) On or about December 14, 2007, SYUME and LEGHESE
spoke by telephone, at which time they prepared for an upcoming meeting
with the Chairperson.
(14) On or about January 10, 2008, SYUME gave the
Chairperson approximately $99,950 in cash as partial payment for
multi-vehicle taxicab company licenses.
(15) On or about January 12, 2008, SYUME and GHIRMAZION
spoke by telephone, at which time they discussed plans to sell
multi-vehicle taxicab company licenses that they had obtained from the
Chairperson.
(16) On or about March 5, 2008, SYUME and LEGHESE spoke
by telephone, at which time they discussed the status of the licenses
for mufti-vehicle taxicab companies that they had obtained from the
Chairperson.
(17) On or about March 6, 2008, SYUME gave the
Chairperson approximately $6,900 in cash as partial payment for multi-vehicle taxicab company
licenses.
(18) On or about March 12, 2008, SYUME gave the
Chairperson approximately $2,000 in cash as partial payment for multi-vehicle taxicab
company licenses.
(19) On or about March 14, 2008, SYUME gave the
chairperson approximately $1,100 in cash as partial payment for multi-vehicle taxicab
company licenses.
(20) On or about April 2, 2008, SYUME and GHIRMAZION
spoke by telephone, at which time they discussed the status of their efforts to
obtain a moratorium on the issuance of multi-vehicle taxicab company licenses.
(21) On or about April 24, 2008, SYUME gave the
Chairperson approximately $3,800 in cash as partial payment for multi-vehicle taxicab company
licenses.
(22) On or about April 29, 2008, SYUME gave the
Chairperson approximately $2,340 in cash as partial payment for multi-vehicle taxicab company
licenses.
(23) On or about May 5, 2008, SYUME gave the Chairperson
approximately $4,980 in cash as partial payment for multi-vehicle taxicab company
licenses.
(24) On or about May 5, 2008, SYUME and LEGHESE spoke by
telephone, at which time they discussed their bribery of the Chairperson;
SYUME stated: " I don't regret a penny I spend on [the Chairperson]."
(25) On or about May 6, 2008, SYUME gave the Chairperson
$962 in cash as partial payment for multi-vehicle taxicab company
licenses.
(26) On or about May 15, 2008, an unindicted
co-conspirator gave the Chairperson approximately $5,000 in cash as
partial payment for multi-vehicle taxicab company licenses.
(27) On or about June 2, 2008, SYUME gave the Chairperson
approximately $3,950 in cash as partial payment for multi-vehicle taxicab company
licenses.
(28) On or about July 5, 2008, SYUME and LEGHESE spoke by
telephone, at which time they discussed their concerns about the Chairperson;
LEGHESE stated: "We have to be careful that [the Chairperson] will not play
any games, do you understand?"
(29) On or about July 7, 2008, SYUME and GHIRMAZION spoke
by telephone, at which time SYUME asked GHIRMAZION to approve the entry
of another into their conspiracy: "Listen, listen. So you will sign
on [co-conspirator's] investor. If you give the approval he will
join."
(30) On or about July 22, 2008, SYUME and GHIRMAZION
spoke by telephone, at which time they discussed financing for their
scheme to obtain corruptly licenses for multi-vehicle taxicab companies.
(Conspiracy to Commit Bribery, Aiding and Abetting,
Causing an Act to Be Done, in violation of Title 18, United States Code,
Sections 371 and 2)
A TRUE BILL:
__________________________
FOREPERSON
__________________________
Acting United States Attorney of the United States in and
for the District of Columbia
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