Case: 4:17-cr-00357-ERW-JMB Doc.

#: 2 Filed: 08/09/17 Page: 1 of 4 PageID #: 7

FILED
AUG -9 2017

UNITED STATES DISTRICT COURT EA~r~rm~~-~~~lc~OJfko

ST.LOUIS
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION

UNITED STATES OF AMERICA, )

)
Plaintiff, )
)
v. ) N~.------------------------~
)
CAROL J. DOTSON, ) 4:17CR00357
'
ERW/JMB
.
)
Defendant. )

INDICTMENT

COUNT ONE
(Wire Fraud)

The Grand Jury charges that:

1. At some time unknown to the Grand Jury but by at least July 21, 2003 and continuing

until at least February 27, 2017 ("the relevant timeframe"), the defendant devised a scheme and

artifice to defraud and to obtain money from K.P., W.J.K.T., W.K.I., W.C. and S.S.M. by means

of false and fraudulent promises, pretenses and representations ..

2. At all times relative to this indictment, K.P., W.J.K.T., W.K.I., W.C. and S.S.M.,

located in Olivette, Missouri, did business as commercial real estate property management

companies. In or about 1990, K.P. hired Carol J. Dotson ("Dotson") as its sole office

administrator.

3. In Dotson's role as office administrator, her duties included handling financial

matters such as collecting and depositing money from clients, maintaining all tenant lease

increases and reconciliations, paying company bills, and distributing monthly financial reports to

all owners.
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,

4. It was part of the scheme to defraud that Dotson wrote checks from the business

accounts ofW.J.K.T., W.K.I. and W.C. to herself for personal benefit and the benefit of others.

At times during the course of the scheme, Dotson wrote multiple checks to herself in a single

month amounting to approximately $20,000.

5. It was further part of the scheme to defraud that, after depositing the checks into her

personal bank accounts, Dotson withdrew large sums of cash to spend on elder care for her

mother, mortgage payments, home renovations, home cleaning services, lawn services, and

shopping at local stores.

6. It was further part of the scheme to defraud that Dotson sent falsified monthly

financial reports to the owners ofK.P., W.J.K.T., W.K.I., W.C. and S.S.M. via email. As part of

the scheme to defraud and to conceal her scheme, Dotson manipulated the monthly financial

reports by decreasing the company's reported revenue by her embezzled amount.

7. It was part of the scheme to defraud that Dotson embezzled over $2 million from

W.J.K.T., W.K.I. and W.C., for her personal benefit, and the benefit of others, during the

relevant timeframe.

8. On or about October 19, 2015, within the Eastern District of Missouri, in furtherance

of the aforesaid scheme to defraud and for the purpose of executing the scheme,

CAROL J. DOTSON,

the defendant herein, knowingly transmitted and caused to be transmitted by means of wire

communication in interstate commerce, between locations in Arizona and the Eastern District of

Missouri, writings, signs and signals, to wit: an email sent by the defendant to the owners of

K.P., W.J.K.T., W.K.I., W.C. and S.S.M. that contained an attached false and fabricated monthly

financial report.

In violation ofTitle 18, United States Code Section 1343.

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(Forfeiture Allegation)

The Grand Jury finds by probable cause that:

1. Pursuant to Title 18, United States Code, Sections 98l(a) and Title 28, United

States Code, Section 2461 (c), upon conviction of an offense in violation of Title 18, United

States Code, Section 1343 as set forth in Count I, the defendant shall forfeit to the United States

of America any property, real or personal, constituting or derived from any proceeds traceable to

said offense.

2. Subject to forfeiture is a sum of money equal to the total value of any property,

real or personal, constituting or derived from any proceeds traceable to said offense(s).

3. Specific property subject to forfeiture includes, but is not limited to, the following:

a. real property located at 7114 Ellendale, St. Louis, Missouri 63143, Parcel No:

47880600600, bearing a legal description as follows: C.B. 4788 S ELLENDALE

PLACE 35FT X 115FT ELLENDALE ADDN LOT I.

b. real property located at 7118 Ellendale, St. Louis, Missouri 63143, Parcel No:

47880600500, bearing a legal description as follows: C. B. 4788 ELLENDALE

56FT 5 5/8 IN/141FT 1 IN X 115FT I 142FT 8 3/8 IN ELLENDALE ADDN:

LOTG-H.

4. If any of the property described above, as a result of any act or omission of the defendant:

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 ofthe court;

d. has been substantially diminished in value; or

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e. has been commingled with other property which cannot be divided without

difficulty, the United States of America will be entitled to the forfeiture of substitute property pursuant

to Title 21, United States Code, Section 853(p).

A TRUE BILL.

FOREPERSON
CARRIE COSTANTIN
Acting United States Attorney

Dianna R. Collins, #59641MO

Assistant United States Attorney