Case 4:15-cr-00203-WTM-GRS Document 27 Filed 12/02/15 Page 1 of 8

UNITED STATES DISTRICT COURT

FILED
U.S. DISTRICT COURT
SAVANNAH DIV.

SOUTHERN DISTRICT OF GEORGIA

2015 DEC -2 'j 5:f9

CLERK
SO. DIST

SAVANNAH DIVISION

61

UNITED STATES OF AMERICA

INDICTMENT NO.

CR415 -203

VIO: 18 U.S.C. 1341

Mail Fraud
CHADWICK L. REESE

18 U.S.C. 1951
Extortion

and
Forfeiture Allegation
JOEL T. MORRIS,
Defendants.

THE GRAND - JURY CHARGES THAT:

Introduction
At all times relevant to this Indictment:
1.

The Chatham Area Transit Authority (CAT) was created by an Act of the Georgia

General Assembly to operate a transit system in Chatham County, Georgia. CAT's yearly
revenues include millions of dollars in passenger fares, local taxes and federal grants.
2

Defendant Chadwick L. Reese was the Executive Director of CAT.

3.

Defendant Joel T. Morris was the CAT Director of Maintenance.

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COUNTS ONE - THREE

Mail Fraud
18 US. C.
4.

ff 1341

Paragraphs 1 through 3 of the Indictment are incorporated by reference as if fully

set forth herein.

5.

Beginning no later than April, 2014, through the return of this Indictment, in

Chatham County, Georgia, within the Southern District of Georgia, and elsewhere, Defendants
Chadwick L. Reese and Joel T. Morris, and others known and unknown to the Grand Jury,
devised and intended to devise a scheme and artifice to defraud and deprive the citizens of
Chatham County and the Chatham Area Transit Authority of their right to honest and faithful
services through bribery, kickbacks and the concealment of material information.
Manner and Means
6.

It was part of the scheme and artifice that the Defendants, aided and abetted by

each other, would secretly use their official positions to enrich themselves by soliciting and
accepting cash and other payments in exchange for rigging the award of CAT contracts to
selected individuals and companies.
7.

It was further part of the scheme and artifice that the Defendants, aided and

abetted by each other, would direct CAT to make payments to individuals and companies who
had been awarded CAT contracts through a rigged and fraudulent process.
It was further part of the scheme and artifice that the Defendants, aided and
abetted by each other, would direct how and when they would receive bribery and kickback
payments.

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9.

It was further part of the scheme and artifice that the Defendants, aided and

abetted by each other, would take steps to hide, conceal, and cover up their bribery and kickback
scheme.
The Mailings
10.

On or about the dates listed below, the Defendants, for the purpose of executing,

and attempting to execute, the scheme and artifice, did knowingly cause to be sent by U.S. Mail
Chatham Area Transit Authority checks in the amounts so listed:
Count

Date of Mailing

Amount of Check

July 17,2015

$19,397.20

September 11, 2015

$13,421.00

October l6,2015

$11,755.76

All done in violation of Title 18, United States Codes, Sections 1341 and 1346.
COUNT FOUR
Extortion
18 US.C. 1951
11.

Paragraphs 1 through 10 of the Indictment are incorporated by reference as if

fully set forth herein.

12.

On or about June 25, 2015, in Chatham County, within the Southern District of

Georgia, and elsewhere, Defendant Joel T. Morris, aided and abetted by others, did knowingly
attempt to obstruct, delay and affect commerce, and the movement of articles and commodities
in commerce, by extortion, in that the Defendant, in his official capacity with Chatham Area
3

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Transit Authority, attempted to obtain money from PW, with that individual's consent, which
was induced under color of official right.
All done in violation of Title 18, United States Code, Section 1951.
COUNT FIVE

Extortion
18 U.S.0 1951
13.

Paragraphs I through 10 of the Indictment are incorporated by reference as if

fully set forth herein.

14.

On or about July 22, 2015, in Chatham County, within the Southern District of

Georgia, and elsewhere, Defendant Chadwick L. Reese, aided and abetted by others, did
knowingly attempt to obstruct, delay and affect commerce, and the movement of articles and
commodities in commerce, by extortion, in that the Defendant, in his official capacity with
Chatham Area Transit Authority, attempted to obtain money from PW, with that individual's
consent, which was induced under color of official right.
All done in violation of Title 18, United States Code, Section 1951.
COUNT SIX

Extortion
18 US.C. 1951
15.

Paragraphs 1 through 10 of the Indictment are incorporated by reference as if

fully set forth herein.

16.

On or about September 15, 2015, in Chatham County, within the Southern

District of Georgia, and elsewhere, Defendant Chadwick L. Reese, aided and abetted by others,

ru

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did knowingly attempt to obstruct, delay and affect commerce, and the movement of articles and
commodities in commerce, by extortion, in that the Defendant, in his official capacity with
Chatham Area Transit Authority, attempted to obtain money from PW, with that individual's
consent, which was induced under color of official right.
All done in violation of Title 18, United States Code, Section 1951.
COUNT SEVEN
Extortion
18 US. C. 1951
17.

Paragraphs 1 through 10 of the Indictment are incorporated by reference as if

fully set forth herein.

18.

On or about September 18, 2015, in Chatham County, within the Southern

District of Georgia, and elsewhere, Defendant Joel T. Morris, aided and abetted by others, did
knowingly attempt to obstruct, delay and affect commerce, and the movement of articles and
commodities in commerce, by extortion, in that the Defendant, in his official capacity with
Chatham Area Transit Authority, attempted to obtain money from PW, with that individual's
consent, which was induced under color of official right.
All done in violation of Title 18, United States Code, Section 1951.
COUNT EIGHT
Extortion
18 US. C. 1951
19.

Paragraphs I through 10 of the Indictment are incorporated by reference as if

fully set forth herein.

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20.

On or about October 26, 2015, in Chatham County, within the Southern District

of Georgia, and elsewhere, Defendant Chadwick L. Reese, aided and abetted by others, did
knowingly attempt to obstruct, delay and affect commerce, and the movement of articles and
commodities in commerce, by extortion, in that the Defendant, in his official capacity with
Chatham Area Transit Authority, attempted to obtain money from PW, with that individual's
consent, which was induced under color of official right.
All done in violation of Title 18, United States Code, Section 1951.
COUNT NINE
Extortion
18 US. C. 1951
21.

Paragraphs 1 through 10 of the Indictment are incorporated by reference as if

fully set forth herein.

22.

On or about October 29, 2015, in Chatham County, within the Southern District

of Georgia, and elsewhere, Defendant Joel T. Morris, aided and abetted by others, did
knowingly attempt to obstruct, delay and affect commerce, and the movement of articles and
commodities in commerce, by extortion, in that the Defendant, in his official capacity with
Chatham Area Transit Authority, attempted to obtain money from PW, with that individual's
consent, which was induced under color of official right.
All done in violation of Title 18, United States Code, Section 1951.
FORFEITURE ALLEGATION
The allegations contained in Counts One through Nine of this Indictment are
hereby realleged and incorporated by reference for the purpose of alleging forfeitures pursuant to

n.

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Title 18, United States Code, Section 981 (a)(1 )(C) and Title 28, United States Code, Section
2461(c).
2.

Upon conviction of one or more of the offenses in violation of Title 18, United

States Code, Section 1341 set forth in Counts One through Three of this Indictment, the
Defendants, Chadwick L. Reese and/or Joel T. Morris, shall forfeit to the United States of
America, pursuant to Title 18, United States Code, Section 981 (a)(1 )(C) and Title 28, United
States Code, Section 2461(c), any property, real or personal, which constitutes or is derived from
proceeds traceable to the offense(s).
3.

Upon conviction of one or more of the offenses in violation of Title 18, United

States Code, Section 1951 set forth in Counts Four through Nine of this Indictment, the
Defendants, Chadwick L. Reese and/or Joel T. Morris, shall forfeit to the United States of
America, pursuant to Title 18, United States Code, Section 981 (a)( 1 )(C) and Title 28, United
States Code, Section 2461(c), any property, real or personal, which constitutes or is derived from
proceeds traceable to the offense(s).
4.

If any of the property described above, as a result of any act or omission of the

Defendants:
a.

cannot be located upon the exercise of due diligence;

b.

has been transferred or sold to, or deposited with, a third party;

C.

has been placed beyond the jurisdiction of the court;

d.

has been substantially diminished in value; or

e.

has been commingled with other property which cannot be divided

without difficulty,

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the United States of America shall be entitled to forfeiture of substitute property pursuant to Title
21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section
2461(c).
All pursuant to 18 U.S.C. 981(a)(1)(C) and 28 U.S.C. 2461(c).

A TRUE BILL.

Foreperson

Edward J. Tarver
United States Attorney

irst Assistant United States Attorney

BrTaffertW
Assistant United States Attorney
Criminal Division Chief
* denotes lead counsel

[4]
LPJ