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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
UNITED STATES OF AMERICA, |
NO. 4:05CR00283HEA |
Plaintiff, |
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vs. |
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CASSANDRA WILLIAMS, |
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| Defendant. |
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INDICTMENT
COUNT ONE
The Grand Jury charges that:
On or about October 28, 2004, in the Eastern District of Missouri,
CASSANDRA WILLIAMS,
the defendant herein, in a matter within the jurisdiction of the Department of Labor, Office of Labor
Management Standards, a department of the United States, knowingly and willfully made materially false,
fictitious and fraudulent statements and representations, to wit: defendant CASSANDRA WILLIAMS advised an
Investigator for the Department of Labor, Office of Labor Management Standards that documents she submitted
that day, including e-mail messages and a letter from the Salvation Army were true and correct, when in truth
and fact, as the defendant CASSANDRA WILLIAMS then knew, she had altered these documents in an attempt to make
it appear that she had made a contribution to the Salvation Army.
In violation of Title 18, United States Code, Section l001(a)(2).
COUNT TWO
The Grand Jury further charges that:
On or about October 28, 2004, in the Eastern District of Missouri,
CASSANDRA WILLIAMS,
the defendant herein, did corruptly influence, obstruct and impede, and endeavor to influence, obstruct and
impede the due and proper administration of the law under which a pending proceeding, to wit: an investigation
by the United States Department of Labor, Office of Labor Management Standards into whether payments made by
the American Federation of Government Employees, Local 905, were lawfully made was being had before the United
States Department of Labor, Office of Labor Management Standards, by presenting to investigators of the United
States Department of Labor, Office of Labor Management Standards documents which the defendant had altered in
an attempt to justify the payments being investigated.
In violation of Title 18, United States Code, Section 1505.
A TRUE BILL.
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FOREPERSON
JAMES G. MARTIN
United States Attorney
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DAVID M. ROSEN #23537
Assistant United States Attorney
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