John Wiley Price Indictment 7.25.2014

Case 3:14-cr-00293-M Document 1 Filed 07/23/14 Page 1 of 109 PageID 1
U.S. DISTRICT COURT
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(\V R\G\~ ~ IN TilE UNITED STATES DISTRICT ( OURT

FOR THE NORTHERN DISTRICT OF rEXAS
3 2014 JUL2
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DALLAS DIVISION ~U.S.D~COUR.T
Deputy
UNITED STATES OF AMERICA
v.
NO. 3 - 14 CR- 2 9 3- M
FILED UNDER SEAL
JOHN WILEY PRICE (01)
a.k.a John Wiley Price III
.I
KATHY LOUISE NEALY (02)
~
'
DAPHENY ELAINE FAIN (03)
CHRISTIAN LLOYD CAMPBELL (04)
INDICTMENT
The Grand Jury Charges:
INTRODUCTION
At all times material to this indictment:
A. DALLASCOUNTY,TEXAS
1. Dallas County, Texas was a political subdivision of the State of Texas,
divided into four geographic precincts also known as "districts."
2. A five-member Commissioners Court was the primary governing body of
Dallas County. The Court was composed of four Commissioners, one elected from each
district, and a County Judge elected countywide.
3. The Commissioners Court presided over a variety of official matters,
including awarding county contracts through a competitive bidding process, building and
maintaining roads and bridges within each County district, and controlling expenditures
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.
of County funds including those that the County received from federal programs
involving grants, contracts, subsidies, loans, guarantees, insurance, or other forms of
federal assistance. The Commissioners Court also set the County tax rate, adopted the
County budget, oversaw the administration of the County government, appointed boards
and commissions, reviewed and/or approved grants and personnel actions, approved the
budget of and set the tax rate for the hospital district, and exercised authority over the
budget of most departments, including those headed by other elected officials.
B. DEFENDANTS
4. Defendant JOHN WILEY PRICE was an elected County Commissioner
of the Dallas County Commissioners Court for District 3 in Dallas County, Texas, in the
Northern District of Texas, from 1985 through the present. Price oversaw the daily
operations of Road and Bridge District 3. He was also actively involved in the decision-
making related to and the direction of the County's information technology (IT) systems
and services, serving on the County's IT Steering Committee that met regularly to discuss
current IT issues, concerns, budgeting, and potential and upcoming IT projects and needs.
The IT Steering Committee also received briefings from County departments, and it
shared information with and made recommendations to the Commissioners Court.
5. Each elected term, Price took an oath specific to County Commissioners
and Judges, in which he swore and affirmed:
I, John Wiley Price, do solemnly swear (or affirm) that I will not be,
directly or indirectly, interested in any contract with or claim against the
County, except such contracts or claims as are expressly authorized by law
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and except such warrants as may issue to me as fees of office. So help me

God.
6. Price also took an official oath and affirmation to faithfully execute the
duties of a County Commissioner, as well as to preserve, protect, and defend the
Constitution and laws of the United States and the Constitution and laws of the State of
Texas, as required by the Texas Constitution, Article 16, Section 1. Included among the
state and local laws that Price promised to uphold, and those applicable to County
Commissioners, was Texas Penal Code, Section 36.02(a)(l) and (3), which provided, in
part, that
a person commits the offense of bribery if he intentionally and knowingly

offers, confers, or agrees to confer on another, or solicits, accepts, or agrees
to accept from another:
(1) any benefit as consideration for the recipient's decision, optmon,

recommendation, vote, or other exercise of discretion as a public servant; or
(3) any benefit as consideration for a violation of a duty imposed by law on

a public servant.
7. Under these state laws and under his oaths of office, Price owed a duty of
honest and faithful services to Dallas County, Texas and its citizens.
8. Texas Local Government Code, Chapter 159 and Texas Government Code,
Chapter 572 required Price to file a financial statement under oath disclosing his
financial activity that included, among other things:
a. occupational income and rental income;

b. interests in businesses, real property, and business entities; and
c. gifts or things of value over $250 from anyone other than a close family
member.
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9. Similarly, Price was required to disclose all sources of income generated
outside of county employment pursuant to Dallas County Commissioners Court Order
2011-507 and Texas Local Government Code, Chapter 159.
10. Defendant KATHY LOUISE NEALY was a local lobbyist who did
business under both a sole proprietorship, Kathy L. Nealy & Associates (KLNA), and a
Texas corporation, KNI, Inc. (KNI). Nealy operated both companies from an office as
well as her home in Dallas County, Texas, in the Northern District of Texas. Nealy was
also registered with the City of Dallas as a lobbyist.
11. Nealy advertised her services to include "political consulting" and
"business consulting" for clients such as "business tycoons" and local politicians,
including Price for each of his campaigns for County Commissioner. As part of her
campaign work for Price, Nealy organized and hosted fundraisers at an art gallery,
Business M(a business known to the Grand Jury). Nealy promised KLNA clients
"access to contacts" necessary to "get the job done."
12. Among Nealy's business clients were vendors seeking contracts with
Dallas County and businesses pursuing other matters on which Price voted in
Commissioners Court.
13. Nealy often arranged meetings, lunches, and dinners with Price for her
business clients that had matters in front of the Commissioners Court, many occurring
during periods when contact with elected officials and other county employees was
prohibited because the selection process for bids on county contracts was in progress at
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the time. Price sponsored and advocated for the interests of Nealy's clients and voted on
these matters in a manner that benefited them, while accepting a stream of financial
benefits from Nealy totaling approximately $950,000.
14. Defendant CHRISTIAN LLOYD CAMPBELL was a commissioned
account manager with one of Nealy's business clients until approximately mid-2004. At
that time, Campbell also began consulting under a sole proprietorship he created,
Campbell Consulting Group (CCG). He and Nealy simultaneously contracted as
"consultants" with several of the same companies that submitted bids for Dallas County
contracts, often with nearly identical contract terms. To maintain favor with Price, on
several occasions, Campbell successfully persuaded vendors to hire Nealy or to renew
her contracts for subsequent years.
15. Defendant DAPHENY ELAINE FAIN, a Dallas County employee,
worked for Price beginning in 1995, first as a secretary, later as his executive assistant,
and finally, as his chief of staff, through the date of this indictment.
C. DALLAS COUNTY CONTRACT BIDDING PROCESS
16. From January 2001 through 2011, Dallas County invited vendors to bid for
contracts to provide services that included IT services and equipment, digital imaging and
indexing of records, inmate telephone service, collection of Justice of the Peace Court
fines, and others. The process would begin when the Commissioners Court voted to issue
a Request for Proposals (RFP) or a Request for Qualifications (RFQ). These requests
were invitations for companies to submit their proposals and qualifications for providing
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a specific product or service to the County and at what cost. Once submitted, an
evaluation committee (also known as a selection committee) composed of county
employees would review, score, and recommend to the Commissioners Court which
vendors should advance in the bidding process. The Commissioners Court would then
vote on whether to accept or reject the committee's recommendations. Frequently, the
Commissioners Court would vote to narrow the bidders to a smaller group of four to six
companies, all of which would submit a second bid that would be their "Best and Final
Offer" (BAFO). The evaluation committee would again review and score the bids and
recommend a final bidder to the Commissioners Court. The Court then voted on whether
the County should enter into contract negotiations with the selected bidder. After
negotiations were finalized, the Court voted again to authorize the County Judge to sign
the contract with the chosen vendor. If the County could not reach an agreement with the
selected vendor, the County could choose to end negotiations with that vendor and begin
negotiating with the next most-qualified vendor until a contract was awarded.
17. State and local law dictated certain procedures to safeguard the
confidentiality of the proposals' contents, prevent disclosure to competing offerors, and
keep the information secret during negotiations between potential vendors and the
County. These included:
a. Texas Local Government Code, Section 262.0225, Additional Competitive
Procedures, which stated, in part:
(a) In the procedure for competitive bidding under this subchapter, the
commissioners court of the county shall provide all bidders with the
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opportunity to bid on the same items on equal terms and have bids judged
according to the same standards as set forth in the specifications.
(b) A county shall receive bids or proposals under this subchapter in a fair
and confidential manner.
b. Texas Local Government Code, Section 262.030, Alternative Proposal
Procedure for Insurance, High Technology Items, and Special Services, which stated, in
part:
If provided in the request for proposals, proposals shall be opened so as to

avoid disclosure of contents to competing offerors and kept secret during
the process of negotiation. All proposals that have been submitted shall be
available and open for public inspection after the contract is awarded,
except for trade secrets and confidential information contained in the
proposals and identified as such.
c. Chapters 74 and 86 of the Dallas County Code, which addressed
confidentiality and required that
all information protected by state statute concerning county business must

be held in strict confidence and must not be discussed with others on or off
the job except for purposes of necessary county business (Section 74-743);
and
all information concerning county business must be held in strict

confidence and must not be discussed with others except for purposes of
necessary county business (Section 86-753).
18. To enforce and comply with Texas law and Dallas County's local code and
transparency policy, Dallas County included in many of its RFPs and RFQs provisions
that prohibited bidders, including agents and representatives, from directly discussing or
promoting their proposals with any member of the Commissioners Court or staff during
the selection process, except in county-sponsored inquiries, briefings, interviews, or
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presentations with the Commissioners Court. This "no-contact period," also known as a
"quiet period," was in place to ensure objectivity and fairness, to keep bidder information
confidential, and to avoid improper or undue influence on the competitive bidding
process.
19. Additionally, the RFPs and RFQs included conflict-of-interest provisions
that prohibited County Commissioners and County employees from having "any financial
interest, direct or indirect, in any contract with the County" and from being "financially
interested, directly or indirectly, in the sale to the County of any land, materials, supplies,
or services," except on behalf of the County as an official or employee.
D. FOREIGN TRADE ZONE DESIGNATION PROCESS
20. In or about 2005, various property owners in Price's district became
interested in developing an area that would accommodate companies involved in
international trade through importing, re-exporting, and/or assembling foreign goods. A
useful amenity for such businesses was to have the property designated as a foreign trade
zone (FTZ), an area physically located within the United States but considered outside
U.S. Customs territory. FTZs were designed to create jobs in the local FTZ area rather
than off-shore. Businesses located within an FTZ received economic benefits that
included (a) not having to pay duties on imported merchandise until it left the FTZ and
entered the U.S. market; (b) not having to pay any duties if the imported merchandise
was re-exported; (c) paying a lower tariff on unfinished or unassembled items later
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incorporated into a final product; and (d) not having to pay local property taxes on
inventory that was imported or that was to be exported.
21. The Federal Foreign Trade Zones Board (FTZB ), an interagency board
consisting ofthe U.S. Secretary of Commerce and the U.S. Secretary ofthe Treasury,
held the authority to grant requests for FTZ designation. To obtain FTZB approval for
property in Dallas County, an application had to be submitted to the Dallas/Fort Worth
International Airport Board, which held the entitlement FTZ grant in the North Texas
area and was the agency responsible for reviewing and approving such applications
before presenting them to the FTZB for its approval.
22. Among other things, the application had to identify the particular properties
for which FTZ status was sought. The properties were not required to be adjacent to one
another, but were expected to be in the same general geographical area with common
attributes. In many cases, before an application was finalized, a public hearing was held
or other public notice was issued to advertise the development of the application, to
determine the interest of other area property owners or parties in joining the application,
and to gauge the support of elected officials and potentially affected businesses in the
area.
23. In addition to a catalog of properties and the proposed zone configuration,
the application also had to include consent letters from each potentially-impacted local
taxing authority - including cities, counties, and school districts - expressing support for
the FTZ designation as to each proposed property. For FTZ applications related to land
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in Dallas County, the Commissioners Court voted to grant or withhold consent for the
proposed FTZ on behalf of Dallas County as a taxing authority. After the FTZB granted
final approval for a particular FTZ, businesses located in that zone were able to "activate"
their facilities with U.S. Customs to take advantage of the FTZ status.
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Count One
Conspiracy to Commit Bribery Concerning
a Local Government Receiving Federal Benefits
(Violation of 18 U.S.C. 371 (18 U.S.C. 666(a)(1)(B) and (a)(2))
24. The allegations set forth in paragraphs one through twenty-three of this
indictment are realleged and incorporated as if fully set forth herein.
25. Dallas County was a local government that received benefits in excess of
$10,000 in each of the consecutive fiscal one-year periods beginning October 1, 2000 and
continuing through October 1, 2010, under a federal program involving a grant, contract,
subsidy, loan, guarantee, insurance, and other form of federal assistance.
26. As the Dallas County Commissioner for District 3, Price was an agent of
Dallas County, Texas.
The Conspiracy and Its Objects
27. Beginning in or about January 2001 and continuing through on or about
June 27, 2011, in the Dallas Division of the Northern District of Texas, John Wiley
Price, Kathy Louise Nealy, and Christian Lloyd Campbell, the defendants, together
with others known and unknown to the Grand Jury, did knowingly combine, conspire,
confederate, and agree together and with each other to give and receive corrupt payments
in violation of Title 18, United States Code, Sections 666(a)(1)(B) and 666(a)(2).
28. It was a part and an object of the conspiracy that Price would and did
corruptly solicit and demand for the benefit of any person, and accept and agree to accept
things of value through a stream of financial benefits, directly and indirectly, from Nealy
and Campbell and others known and unknown to the Grand Jury, intending to be
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influenced and rewarded in connection with any Dallas County business, transaction, and
series of transactions involving anything of value of$5,000 or more, as specific
opportunities arose, in violation of Title 18, United States Code, Section 666(a)(1)(B).
29. It was also a part and object of the conspiracy that Nealy and Campbell
and others known and unknown to the Grand Jury would and did corruptly give, offer,
and agree to give things of value through a stream of financial benefits, directly and
indirectly, to Price with the intent to influence and reward Price in connection with any
Dallas County business, transaction, and series of transactions involving anything of
value of $5,000 or more, as specific opportunities arose, in violation of Title 18, United
States Code, Section 666(a)(2).
30. It was also a part and object of the conspiracy for Price, Nealy, Campbell,
and others known and unknown to the Grand Jury to unjustly enrich themselves as well
as to furnish funds to Nealy to continue funneling things of value through a stream of
benefits to Price.
Manner and Means of the Conspiracy
To achieve unlawful objects of the conspiracy, Price, Nealy, and Campbell used
the following manner and means, among others:
31. During a period that included the years beginning in or about 2001 to in or
about June 2011, Nealy obtained lobbying or consulting agreements with businesses
seeking contracts with Dallas County or that had other business matters in Dallas County
on which the Commissioners Court voted. These businesses knew that Nealy had access
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to and influence with Price. At some point in the process, these businesses would hire
Nealy, and through Nealy, they would obtain inside information about competitors' bids
and other strategically helpful information, which they used to pursue and obtain
lucrative contracts with Dallas County. These businesses often continued to pay Nealy
for the duration of the businesses' dealings in Dallas County, so that, in exchange, Price
would continue to take beneficial actions on their behalf in his capacity as a County
Commissioner, including providing non-public internal Dallas County memos, emails,
and discussions about issues that arose during the performance of such contracts;
advocating on their behalf to the Commissioners Court, to committees on which Price
served including the IT Steering Committee, to the County's Purchasing Department, and
to others; approving additional necessary funding on their contracts; providing
information as to contemplated RFPs or contract renegotiations under consideration by
Dallas County; and refraining from voting in a negative manner or otherwise taking
positions on issues that would negatively impact the businesses' interests.
32. Campbell often contracted as a consultant with several of the same
companies as Nealy, often with nearly identical contract terms. Together with Price,
Campbell facilitated Nealy's continued employment with these businesses by promoting
her to them and compelling the renewal of her contracts. Campbell also ensured that
Nealy's monthly fees were paid, paying her out of his own compensation when
necessary, and he sometimes wrote status reports for Nealy so that she could insert the
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information into her own invoices and ostensibly appear to be providing all of the
services called for in her contracts.
A. CORRUPT PAYMENTS AND BENEFITS TO PRICE
33. While earning income from her lobbying agreements with such vendors and
companies, Nealy provided a stream of financial benefits to Price in the form of money,
cars, and land, totaling approximately $950,000.
Monev
a. Nealy paid Price approximately $447,217 in the form of checks, cash, and
transfers from Nealy's bank accounts to Price's bank accounts.
Cars
b. Nealy also provided to Price the full use of a new Chevrolet Avalanche
approximately every four years and a BMW 645Ci convertible, which Nealy titled and
insured in her name and on which she made monthly car payments and insurance
premium payments, all totaling approximately $191,130.
Land
c. Nealy secretly funneled approximately $198,284 to Price through four
purchases of real property for Price, with Nealy serving as a straw purchaser. Nealy paid
for the properties' purchase, monthly mortgage payments, property taxes, insurance, and
repairs. The properties included a parcel of land referred to as the "Canton" property in
VanZandt County, and three adjacent lots located on South Lancaster Road in Dallas
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(***2, ***8, and ***0 S. Lancaster Road, the locations of which are known to the Grand
Jury).
Rental income
d. Nealy provided Price rent payments totaling approximately $113,600 from
a tenant occupying a building at one of the Lancaster Road properties and operating as
Business T(a business known to the Grand Jury).
34. Price received the following concealed financial benefits from Nealy:
Calendar year 2001

Money paid to Price by Nealy $11,500
(beginning late 2001)
Calendar year 2002 Money paid to Price by Nealy $111,320
Money paid to Price by Nealy $9,100
New 2002 Chevrolet Avalanche

2002 to 2006 $23,690
paid for by Nealy
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2006 to 2010 $36,362
paid for by Nealy

2010 to June 2011 $9,079
paid for by Nealy
New 2005 BMW 645Ci paid

2004 to June 2011 $105,493
for by Nealy
Vehicle insurance costs paid by

2002 to June 2011 $16,506
Nealy
Purchase of ***2 S. Lancaster
2003 to 2008 Road and loan payments paid $46,129
by Nealy
Purchase of ***0 S. Lancaster

2003 $6,502
Road paid by Nealy
Purchase of ** *8 S. Lancaster
2004 $6,600
Road paid by Nealy
Purchase of Canton property
2002 to 2007 and loan payments paid by $94,930
Nealy
Property taxes and insurance for
2002 to June 2011 Lancaster Road and Canton $44,123
properties paid by Nealy
Rental payments from Business
2003 to June 2011 $113,600
Tat S. Lancaster Road
$950~31
35. These payments and benefits described in paragraphs 33 and 34 were made
in furtherance of the conspiracy and to achieve its objects, and to influence and reward
Price to take action or refrain from taking negative action, as specific opportunities arose,
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to benefit Nealy's and Campbell's clients in connection with their pursuit of Dallas
County contracts or other matters voted upon by the Dallas County Commissioners, each
of which was valued at $5,000 or more.
Concealment
36. To conceal the fact that Price was the intended recipient of this continuous
stream of bribe payments, as well as the high number of checks and large quantity of
money Nealy provided to him, Nealy would transfer money from her accounts to Price's
accounts and write checks payable (a) to financial institutions at which Price held
accounts; (b) to herself, which Nealy then endorsed and gave to Price, sometimes with
"salary" written in the memo line; and (c) directly to Price, with various notations in the
memo line in an effort to conceal the true illegal purpose of such payments.
37. Nealy also paid Price by endorsing over to Price third party checks
payable to herself or KLNA, which Price cashed or deposited in his own accounts.
38. Nealy wrote such checks from nine different business, personal, and
investment accounts that Nealy opened for herself, KLNA, and KNI in an effort to
conceal the volume and dollar value of the checks she provided to Price.
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..
B. BENEFITS TO OTHER PERSONS CORRUPTLY SOLICITED AND

DEMANDED BY PRICE
39. In addition to the above-described financial benefits for himself, Price
corruptly solicited and demanded a series of benefits for other persons, with the intent to
be influenced and rewarded in connection with any Dallas County business, transaction,
and series of transactions involving anything of value of$5,000 or more, as specific
opportunities arose. These benefits included:
a. having vendors enter into or renew consulting agreements with Nealy so
that Nealy would (i) personally benefit from the compensation provided under the
contracts and (ii) have the means to continue funneling a stream of financial benefits and
other things of value to Price;
b. hiring and promoting certain individuals known to the Grand Jury,
including C.K., the daughter of a Texas politician and close friend of Price, and H.T.,
who, while employed by a Nealy business client, championed the renewal of Nealy's
contract and covertly increased Campbell's pay so Campbell could pay Nealy during an
RFP selection period; and
c. granting particular minority subcontractors specified by Price a certain
percentage of the bids submitted for contracts in Dallas County and other jurisdictions,
including Business 0 and Business Q (businesses known to the Grand Jury).
C. PRICE'S FAVORABLE OFFICIAL ACTIONS
40. In furtherance of the conspiracy and to effect its objects, Price, while he
was receiving this stream of benefits, took or agreed to take a series of favorable actions
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or to refrain from taking negative actions, as specific opportunities arose, concerning
matters that clients of Nealy and Campbell had before the Dallas County Commissioners
Court, including, among others:
a. On multiple occasions, Price leaked to Nealy and Campbell confidential
information related to specific RFPs that was contained in bidders' materials, internal
Dallas County memoranda, and other documents concerning details of bidders' pricing,
minority subcontractor participation, bid-evaluation scoring and other results, and Dallas
County personnel and committee recommendations.
b. Price leaked internal Dallas County documents and information to Nealy
and Campbell about potential Dallas County projects prior to the County's issuing
publicly available RFPs, to provide Nealy's clients a strategic advantage when pursuing
Dallas County opportunities.
c. During the no-contact period of the bidding process, Price met with or
otherwise communicated with Nealy, Campbell, and their clients that had submitted
proposals in response to Dallas County RFPs.
d. In briefings, committee meetings, discussions with other Commissioners,
and Commissioners Court sessions, Price advocated and voted in favor of or against
actions in a manner that benefited Nealy's and Campbell's clients, including, among
others, whether to: (i) advance Nealy's and/or Campbell's clients forward in the vendor
selection process; (ii) award Dallas County contracts to Nealy's and/or Campbell's
clients; (iii) authorize extensions, modifications, renegotiations, or additional funding of
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existing contracts with Nealy's and Campbell's clients; and (iv) consent to or delay FTZ
designations for land developments located in Price's district.
41. Price acted favorably on behalf of, or refrained from opposing, the
following businesses represented by Nealy and Campbell, among others:
Business S
42. Business S, an IT Services company known to the Grand Jury, conducted
interstate and international business, including in the Dallas Division of the Northern
District of Texas.
43. From approximately 2001 to 2004, Business S pursued contracts with
Dallas County related to IT services. Among the IT contracts that Business S pursued
was the IT Outsourcing RFP No. 2002-011-1007. The County issued the RFP in October
2001 on Price's motion, seeking a vendor to provide comprehensive IT services for all
Dallas County offices, including data management, network management,
telecommunications services, help-desk service, disaster recovery, and equipment
maintenance.
44. Business S, one of five responding vendors, submitted its bid on December
17,2001. Campbell was employed by Business S as an account manager assigned to
handle Dallas County matters at the time. After submitting a bid, Business S retained
Nealy for her access to and influence with Price to persuade him to sponsor Business Sin
the selection process and to provide information helpful in pursuing the contract. Price
made several motions in Commissioners Court that advanced Business S through the
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selection process, and he voted to award it the IT Outsourcing RFP. Business S held the
contract until approximately mid-2004, when it sold most of its IT services assets to
Business A (a company known to the Grand Jury).
45. Nealy initially agreed to assist Business Sin advancing past the first
Commissioners Court vote to decide which competing vendors would proceed forward in
the RFP process. For this assistance, she charged Business S $60,000, paid in eight
$7,500 installments. After Business S advanced to the next RFP stage, it again hired
Nealy, paying her $5,000 per month plus a "success" fee if Dallas County awarded it the
IT Outsourcing contract. Thereafter, through approximately 2004, Business S renewed or
extended new contracts to Nealy for providing "direct communication to appropriate
decision makers" including "elected officials and staff'; providing "timely and relevant
information [to Business S] regarding critical success factors"; and assisting Business Sin
its efforts to be "short-listed" and/or awarded future contracts, including the County's
potential Oracle upgrade and IT outsourcing for Parkland Hospital, under the County's
consideration at that time. Nealy also promised to "leverage established contacts at
Dallas County to assure that [Business S] enjoys an excellent relationship throughout
current contracts [sic] primary term." Business Spaid Nealy a total of approximately
$258,000 under her consulting agreements through 2004.
46. Price, having accepted and agreed to accept the stream of financial benefits
from Nealy described in paragraphs 33 and 34, took actions as specific opportunities
arose that advanced Business S' s interests, including:
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a. Price made a motion and voted in favor of advancing Business S forward in
the IT Outsourcing RFP process in February 2002, which allowed Business S to submit a
presentation to the Commissioners Court and a BAFO for the contract.
b. Price made a motion and voted in favor of selecting Business S as the
preferred IT Outsourcing vendor with whom to begin contract negotiations in late April
2002.
c. Price made a motion and voted in favor of approving the IT Services
Master Agreement and fourteen Service Level Agreements between Dallas County and
Business Sin May 2002. The combined agreement was a five-year contract worth
approximately $40 million, with the option of two 1-year extensions.
d. Price signed a recommendation letter for Business Sin January 2003,
praising the company's work in Dallas County, when Business S was pursuing public
sector contracts in Florida and elsewhere.
e. Price seconded a motion and voted to approve Business S to perform an
Oracle upgrade assessment for the County in June 2003, at a cost of approximately
$200,000.
4 7. While Price publicly advocated for and sponsored Business S in the above-
described manner, Price, Nealy, and Campbell conducted secret, concealed transactions
to advance Business S's interests and to unlawfully enrich themselves and others known
to the Grand Jury, conduct they hid and attempted to hide from Dallas County, RFP
selection committee members, the IT Steering Committee, members and employees of
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the Commissioners Court, competing vendors, and Dallas County citizens. These
transactions included the following acts, among others:
a. Nealy paid Price approximately $218,000 in more than 70 separate
financial transactions.
b. Price accepted from Nealy the new 2002 Avalanche and 2005 BMW
described in paragraphs 33 and 34 for his use and control, while Nealy made car
payments totaling approximately $18,000 during the span of her Business S contracts.
c. Nealy spent approximately $89,000 for the purchases of and monthly loan
payments for the Canton and Lancaster Road properties for Price, as described in
paragraphs 33 and 34.
d. Price, directly and through Campbell, forced Business S to renew Nealy's
expired March 2003 contract by (i) arranging meetings with Business S managers, (ii)
writing letters to Business S senior executives using veiled language, including one in
which he referenced a "deviation on ... promises made in the outset of this venture," and
(iii) emailing upper management to address this concern.
e. At Price's insistence, and with pressure from Nealy and Campbell, in
early May 2003, Business S hired C.K., an individual whom Campbell noted in an email
was the daughter of a certain politician and "close personal friend of Commissioner
Price."
f. Price, through Nealy and Campbell, pressured Business S to award
subcontractor agreements to specific minority companies identified by Price, including
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Business Q, for contracts Business S sought in other jurisdictions unrelated to Dallas
County.
g. Price leaked to Nealy internal Dallas County documents about the
County's IT projects and needs, budget information, and recommendations about the
County's potential courts-management systems project and others that Business S was
pursuing during the span of its consulting contracts with Nealy.
h. Nealy's payments to Price included money transfers or cash withdrawals
from Nealy's accounts deposited into Price's accounts, Nealy's split-deposits of third-
party checks between her accounts and Price's, and checks from Nealy that Price cashed
in exchange for stacks of$100 bills. Nealy's stream of payments to Price included
transactions during the IT Outsourcing RFP selection period, such as, for example:
( 1) One month before Price moved to advance Business S forward in the
IT Outsourcing RFP process, Nealy paid Price $3,000 by transferring funds from
her KLNA business account into Price's account at City Bank in Forney, Texas,
where she and Price both held accounts.
(2) Nealy paid Price another $5,000 in the month following this vote.
(3) The day before Business S's presentation to the Commissioners
Court, Nealy paid Price $2,500.
(4) One week after the presentation, Nealy paid Price an additional
$5,000 in cashiers checks Nealy bought from City Bank.
Page 24 of 107
(5) Three days before Business S submitted its BAFO, Nealy paid Price
$4,500 by directing City Bank to split-deposit a $7,000 third-party check payable
to her company, KLNA, as follows: $4,500 into an account Price held in a
nominee name (of a family member) over which he had sole control, $1,000 into
Nealy's personal account, and $1,500 in cash.
(6) Four days before Price made a motion in Commissioners Court to
select Business S as the preferred IT Outsourcing vendor and begin contract
negotiations, Nealy paid Price $10,000 by writing two separate, sequentially-
numbered $5,000 checks to Price from her KLNA business account, dated the
same day.
(7) On the same day that Price made a motion in Commissioners Court
to approve the IT Services Master Agreement and fourteen Service Level
Agreements between Dallas County and Business S, Nealy paid Price $2,500 by
transferring the funds from her KLNA account to Price's nominee account at City
Bank.
Business A
48. Business A was an IT services company that conducted interstate and
international business, including in the Dallas Division of the Northern District of Texas.
49. In mid-December 2003, Business S advised Dallas County that it planned to
sell most of its IT services assets to Business A and that the current president of that
division of Business S and all personnel supporting the IT Outsourcing contract would be
Page 25 of 107
retained by Business A. In June 2004, on Price's motion, Dallas County consented to this
change and amended its contract to substitute Business A. Business A provided services
to Dallas County until the conclusion of its contract in approximately October 2007.
50. Upper management that transitioned from Business S to Business A adopted
Nealy's $5,000 monthly consulting agreement previously signed with Business S. Based
on Nealy's proven in-roads with Price in prior years, Business A's management
continued to renew Nealy's contract with the expectation that she would provide access
to and influence with Price to (a) help secure future Dallas County contracts, including a
contract to upgrade Dallas County's Oracle Financials system, and (b) maintain a
favorable relationship with Price concerning its existing contract with Dallas County at
that time. When Business A's IT contract with Dallas County ended in approximately
October 2007, Business A terminated Nealy's contract. Business A paid Nealy
approximately $229,000 from June 2004 to 2007.
51. Campbell remained employed as a commissioned account manager for
several months following the transition to Business A, identifying himself as Business A's
point of contact in its March 2004 proposal to Dallas County for the Oracle upgrade
mentioned in Nealy's contract. Then, in approximately June 2004, Campbell ended his
tenure as an employee and became a consultant for Business A under an agreement
similar to Nealy's, with a $7,500 monthly fee and a commission for each contract he
procured. In mid-2007, Business A renewed Campbell's consulting contract with a
$5,000 monthly fee and commissions.
Page 26 of 107
arose that advanced Business A's interests, including:
a. Price made a motion and voted in favor of accepting the change of control
from Business S to Business A and amending the IT Outsourcing contract to reflect
Business A as the vendor in June 2004.
b. Price granted meetings with Business A management, Nealy, and
Campbell concerning Business A's performance of its contracts and other issues that
arose during that time.
c. Price advocated on behalf of Business A to fellow Commissioners, IT
Steering Committee members, and others concerning Business A's perfotTIJ.ance of its
contracts and other issues that arose during that time.
53. While Price publicly advocated for and sponsored Business A in the above-
to advance Business A's interests and to unlawfully enrich themselves and others known
a. During the negotiations between the County and Business A regarding the
contract terms under which Business A would assume Business S' s IT Outsourcing
Page 27 of 107
contract, Nealy and Price shared and discussed internal County information and Business
A's responses to such information.
b. Price met with Nealy privately to share inside Dallas County information
about Business A and had staff members fax and email internal Dallas County documents
summarizing discussions about Business A's performance with the County.
c. Nealy paid Price on or near dates on which her calendar reflected meetings
with Price concerning Business A.
d. Approximately six days before a November 2004 Dallas County meeting
attended by Price to discuss issues related to Business A's performance, Nealy purchased
a 2005 BMW that she provided to Price for his use.
e. Price also accepted from Nealy the 2007 Avalanche described in
paragraphs 33 and 34 for his use and control, while Nealy made car payments totaling
approximately $81,000 during the span of her Business A contracts.
f. Nealy spent approximately $148,000 on the four properties she bought for
Price, described in paragraphs 33 and 34.
g. Throughout the period of Nealy's contracts with Business A, Nealy paid
Price approximately $153,000 in more than 45 separate financial transactions, including
checks from Nealy that Price deposited into his nominee account at City Bank or cashed
in exchange for stacks of $100 bills, and checks that Nealy wrote to herself or to Dallas
Telco and gave to Price to cash or deposit.
Page 28 of 107
Business B
54. Business B was a company known to the Grand Jury that conducted
interstate business, including in the Dallas Division of the Northern District of Texas.
55. During a period that included the years 2004 through 2009, Business B
pursued contracts with Dallas County related to, among other things, digitizing County
records and countywide cashiering services. One such contract was the Dallas County
Recording, Indexing, and Imaging RFP No. 2004-064-1485, issued by the County in or
about March 2004, seeking a vendor to digitize Dallas County Clerk's Office records
(hereinafter, DCRIIS RFP). Bids were due from vendors on April19, 2004.
56. The DCRIIS RFP contained a "no-contact" provision in effect during the
selection process that prohibited firms from contacting County staff and prohibited "firms
and their employees of related companies, including paid or unpaid personnel acting on
their behalf," from contacting or participating in "any type of contact outside the County
offices with County employees, including elected officials." To further safeguard the
confidentiality of bidders' information, the RFP also relayed that "all Proposal
Information, including detailed price and cost information, shall be held in confidence
until the contract is awarded and/or cancelled."
57. Initially, Nealy teamed with Business Bas a subcontractor for the DCRIIS
RFP. Nealy was to provide "an outreach and education program" that involved
providing marketing materials to the public and training to users of the indexing and
imaging system. After submitting its initial proposal to the County, Business B
Page 29 of 107
negotiated with Nealy as to how much it would pay her for her piece of the contract, at
one point offering her $50,000.
58. Campbell signed a consulting agreement with Business B shortly before
the company submitted its proposal to Dallas County. Mirroring Nealy's 2004 contract
with Business S, Campbell promised to "leverage established relationship's at Dallas
County" to help Business B win the DCRIIS contract, in exchange for $5,000 monthly
payments to Campbell and a $25,000 success fee.
59. On Price's motion, Business B advanced to the second round of the RFP
process with three other vendors in late May 2004. Business B presented a demonstration
of its proposed system to the selection committee the following month. After vendor
presentations, however, the selection committee recommended eliminating Business B
and a second bidder from further consideration, noting in a confidential memo to the
Commissioners Court that Business B' s bid included a costly marketing proposal.
60. Price convinced fellow Commissioners to reject the DCRIIS selection
committee's recommendation. On Price's motion, the Commissioners Court voted to
keep Business B in the selection process and move forward with three other vendors for
the DCRIIS RFP, thereby deviating from the typical RFP process.
61. Business B ultimately submitted the lowest BAFO without the marketing
piece of its proposal and without Nealy as a subcontractor, due to the County's comments
that the RFP did not call for a marketing program. Business B was selected as the
DCRIIS RFP finalist in late January 2005. It signed a five-year contract with the County,
Page 30 of 107
worth approximately $3.2 million, in late March 2005, which it held until in or about
2009.
62. After eliminating Nealy as a subcontractor in its BAFO, Business B hired
her as a lobbyist at the local government level for a $4,000 monthly fee and additionally
paid her approximately $50,000 to market its services. It also renewed Campbell's
consulting contract. The company continued to retain Nealy until2008, but ended
Campbell's contract in approximately February 2007. In internal discussions regarding
whether to renew Nealy's yearly contract, one Business B manager advocated in favor of
it, noting that Nealy "is very close to the strongest Commissioner, Commissioner Price"
and very close to a partner in Business L, another Dallas County vendor (known to the
Grand Jury) with which Business B was seeking to do business.
63. In total, Nealy was paid approximately $197,000 from Business B.
arose that advanced Business B' s interests, including:
a. Price made a motion and voted in favor of advancing Business B forward
to the second step of the DCRIIS RFP process involving product demonstration in May
2004.
b. Price successfully advocated for Business B to remain in the selection
process, convinced fellow County Commissioners to reject the DCRIIS selection
committee's recommendation to eliminate Business B from further consideration, made a
Page 31 of 107
motion in Commissioners Court to that effect, and voted in favor of advancing Business
B in the selection process in August 2004.
c. Price voted to select Business B as the finalist for the DCRIIS RFP and to
begin contract negotiations with Business Bin January 2005.
d. Price voted to advance Business B to the next phase of the Countywide
Receipting System RFP -another Dallas County RFP that Business B pursued, estimated
to be worth approximately $3.4 million- in January 2005.
e. Price voted to authorize the County Judge to sign a five-year agreement
with Business B, worth approximately $3.2 million, for the DCRIIS project in March
2005.
f. Price voted to approve an amendment to Business B' s DCRIIS contract,
providing for additional services related to the DCRIIS project at an added cost of
approximately $238,000, in November 2007.
65. While Price publicly advocated for and sponsored Business Bin the above-
to advance Business B's interests and to unlawfully enrich themselves and others known
Page 32 of 107
a. Nealy obtained the DCRIIS selection committee's internal memo to the
Commissioners Court recommending eliminating Business B from the process, which
was marked "CONFIDENTIAL- Not for distribution" and contained the committee's
rationale for its recommendation, discussions about each vendor, the dollar amounts of
each bid, and other confidential information. At that time, Business B' s bid was the
highest of the four competing vendors, but it ultimately submitted the lowest final offer.
b. After Price's August 2004 success in keeping Business Bin the DCRIIS
RFP process, Campbell funneled $7,500 to Nealy by amending his contract with
Business B for two months so that he would be paid an additional $5,000 each month on
top of his original $5,000 compensation, which he then used to pay Nealy. Upon
depositing Campbell's $7,500 into her business account, Nealy immediately paid Price
$2,500.
c. Nealy and Price contacted each other multiple times about Business B
during the no-contact period of the DCRIIS RFP process.
d. Nealy obtained a second internal Dallas County memo marked
"Confidential- Not for Distribution," issued by the DCRIIS selection committee to the
Commissioners Court after each vendor submitted its BAFO. Among other information,
the memo contained the committee's scoring summary of the four finalists' bids and each
of their BAFO pricing.
e. During the time of the Countywide Receipting System RFP, Price faxed to
Nealy an internal memo in March 2005 that the County's purchasing agent had provided
Page 33 of 107
to the IT Steering Committee, relaying that the evaluation committee recommended not
advancing Business B in the RFP process. Price's fax also included the evaluation
committee's scores of each competing vendor and the dollar figures of their bids.
f. Price contacted Business B to request that H.T. be promoted, after H.T.
persuaded Business B to renew Nealy's contract in 2006 because of Nealy's close
association with Price and her close ties with a partner of Business L.
g. Price accepted from Nealy the new 2005 BMW and the new 2007
Avalanche described in paragraphs 33 and 34 for his use and control, while Nealy made
car payments totaling approximately $117,000 during the span of her Business B
contracts.
h. Nealy spent approximately $170,000 on the four properties she bought for
1. Throughout the span of Nealy's contracts with Business B, Nealy paid
Price approximately $176,000 in over 60 separate financial transactions, many of which
were checks from Nealy that Price deposited into his nominee account at City Bank or
cashed in exchange for stacks of $1 00 bills, and checks that Nealy wrote to herself or to
Dallas Telco and gave to Price to cash or deposit. Nealy's stream of payments to Price
included transactions during the DCRIIS selection period, such as, for example:
(1) The day after Price moved to advance Business B forward in the
DCRIIS RFP process in May 2004, Nealy paid Price $3,500.
Page 34 of 107
(2) The day before Nealy was scheduled to meet with Price and
Campbell regarding Business B in June 2004, during the DCRIIS RFP no-contact
period, Nealy paid Price $2,000.
(3) The day before Price voted to authorize the County Judge to sign the
approximately $3.2 million DCRIIS contract with Business Bin March 2005,
Nealy paid Price $1,000.
Businesses V and U
66. Business V was an IT services company known to the Grand Jury that
conducted interstate business, including in the Dallas Division of the Northern District of
Texas.
67. Business U was an IT services company known to the Grand Jury that
Texas.
68. During a period that included the years 2006 to 2010, Business V partnered
with various vendors, including Business U, that submitted bids for IT contracts in Dallas
County. In or about early November 2006, Business V signed a consulting contract with
Nealy to "make introductions," "attend meetings," and "lobby on behalf of [Business Ji1"
in Dallas County and other local venues, in exchange for a $2,000 monthly fee and
commissions on new business generated. Nealy lobbied on behalf of Business V under
yearly-renewed contracts until in or about January 2010. She was paid approximately
$159,000 by Business Vthroughout that period.
Page 35 of 107
69. Business Vutilized Nealy for access to and information from Price
concerning several RFPs, including:
a. the IT Help Desk Provider RFQ No. 2007-071-2776, issued by Dallas
County in March 2007, for which Business V partnered as a subcontractor with Business
U and for which a three-year contract worth at least $2 million was awarded to another
vendor in September 2007;
b. the County's Desktop Technical Support RFP No. 2007-117-3023, issued
in July 2007, for which Business V also partnered as a subcontractor with Business U and
for which a five-year contract worth approximately $8.5 million was awarded in late
November 2007 to another vendor, Business C (a company known to the Grand Jury),
over Price's objections; and
c. the Inmate Phone System RFQ No. 2007-082-2822 to provide inmate
phone services for the Dallas County jail facilities, issued in April2007, for which a five-
year contract, estimated to generate approximately $6 million in commissions for the
County, was awarded in June 2008 to Business U.
70. All three RFP/RFQs contained identical "no-contact" provisions in effect
throughout the selection process, which stated:
Upon release ofthe proposal, firms and their employees of related companies as
well as paid or unpaid personnel acting on their behalf shall not contact or
participate in any type of contact with County employees, including elected
officials. Such contact may result in the vendor being disqualified. All contact
must be coordinated through {the/ Purchasing Supervisor, (or this procurement.
Page 36 of 107
71. Additionally, the RFP/RFQs mandated that, in accordance with State of
Texas guidelines, to obtain the best value for the County through a negotiated
procurement process, "[a]ll information will be kept confidential until a contract is
formally executed or the [RFPIRFQ] is cancelled."
arose that advanced Business V' s and Business V' s interests, including:
a. Price voted in favor of advancing Business U and Business C as finalists in
the Desktop Technical Support RFP in September 2007.
b. Price voted "NO!" against authorizing contract negotiations with Business
C (Business V's competitor) as the selected vendor for the Desktop Technical Support
RFP inN ovember 2007.
c. Price voted "NO!" against awarding the Desktop Technical Support RFP to
Business C and against authorizing the County Judge to sign a contract with Business C
in late November 2007.
d. Price voted in favor of advancing Business U and three others in the Inmate
Phone System RFQ process in July 2007.
e. Price seconded a motion and voted in favor of selecting Business U as the
vendor for the Inmate Phone System RFQ and entering into contract negotiations with
Business U in March 2008.
Page 37 of 107
f. Price made a motion and voted to award the Inmate Phone System RFQ to
Business U and to authorize the execution of a five-year contract estimated to generate
approximately $6 million in commissions for the County in June 2008.
73. While Price publicly advocated for and sponsored Businesses Vand U in
the above-described manner, Price and Nealy conducted secret, concealed transactions to
advance Business V' s and Business U' s interests and to unlawfully enrich themselves and
others known to the Grand Jury, conduct they hid and attempted to hide from Dallas
County, RFP selection committee members, the IT Steering Committee, members and
employees of the Commissioners Court, competing vendors, and Dallas County citizens.
These transactions included the following acts, among others:
a. During the no-contact period of the Desktop Technical Support RFP, Price
forwarded to Nealy internal Dallas County emails from the County's purchasing agent
and the County's chief information officer (CIO) discussing Business U's bid for that
RFP.
b. Also during the no-contact period of the Desktop Technical Support RFP,
Nealy obtained a confidential, internal Dallas County memo from the County's
purchasing agent to the Commissioners Court in late October 2007 entitled, "Additional
Information on Award Recommendation," that compared the BAFOs of Business U and
Business C, the two finalists for the RFP, including pricing, negotiation points, and
minority subcontractor participation for each business.
Page 38 of 107
c. The day after the date of the confidential memo, an executive with Business
U emailed Nealy a letter from Business U to Price, responding point-by-point to the
confidential, internal Award Recommendation memo that Nealy obtained. Price had a
staff member email Business U's letter to the County's CIO.
d. Price then forwarded to Nealy the County CIO's and County purchasing
agent's confidential analysis of and response to Business U's letter to Price.
e. Price continued to leak confidential and internal information to Nealy
during the no-contact period of the Desktop Technical Support RFP by forwarding to
Nealy internal County emails from the County's purchasing agent with financial
information about Business C that Price had requested in the Commissioners Court
session the prior week.
f. Two days before the final Commissioners Court vote on the Desktop
Technical Support RFP, while the no-contact period was still in effect, Price leaked
sensitive, inside information to Nealy about Business C by forwarding to Nealy an
internal County email chain between the County's CIO and the County's purchasing
director discussing potential negotiation points and revisions to the County's proposed
contract with Business C. In the email chain, a County employee noted that "[a]t
Commissioner Price's request I have added him to the distribution of this response." The
email Price forwarded to Nealy also included a copy of the proposed contract with
Business C.
Page 39 of 107
g. The next day, Nealy forwarded to Business Vthe confidential email chain
that Price sent to Nealy, including the proposed Desktop Technical Support contract with
Business C.
h. During the no-contact period of the Inmate Phone System RFQ, Price
agreed to meet with Nealy and representatives from Business U on multiple occasions,
including during the period when the County was engaged in ongoing negotiations with
Business U for that contract.
1. Price continued to drive the 2005 BMW, the new 2007 Avalanche, and
eventually the new 2010 Avalanche from Nealy described in paragraphs 33 and 34 for his
use and control, while Nealy made car payments totaling approximately $92,000 during
the span of her Business V contracts.
J. Nealy spent approximately $83,000 on the four properties she bought for
k. Throughout the span of Nealy's contracts with Business V, Nealy paid
Price approximately $122,000 in over 55 separate financial transactions, many of which
were checks Nealy wrote to Dallas Telco that Price deposited or cashed in exchange for
stacks of$100 bills. Nealy's stream of payments to Price included transactions during
the RFP/RFQ selection periods, such as, for example:
(1) The week before Price voted to advance Business U to the next
stage of the Desktop Technical Support RFP, Nealy paid Price $5,000.
Page 40 of 107
..
(2) In the month surrounding Price's leaks to Nealy of confidential
information regarding the Desktop Technical Support RFP vendor proposals and
contract negotiations, Nealy paid Price $5,500.
(3) In the week following Price's vote to advance Business U to the
next stage of the Inmate Phone System RFQ, Nealy paid Price $2,500.
Business 0
74. Business Q was an IT services company known to the Grand Jury that
Texas.
75. During a period that included the years 2001 to 2011, Business Q pursued
contracts with Dallas County related to, among other things, IT and desktop technical
support services. In late August 2010, Dallas County issued Desktop Technical Support
Services RFP No. 2010-090-5232, seeking a vendor to provide technical expertise to
support over 5,500 Dallas County computer users.
76. As with previous RFPs, the Desktop Technical Support RFP contained a
"no-contact" provision in effect throughout the selection process, which stated:
Upon release o(the proposal, firms and their employees of related companies as
well as paid or unpaid personnel acting on their behalf shall not contact or
participate in any tvpe of contact with Countv employees, including elected
officials. Such contact may result in the vendor being disqualified. All contact
must be coordinated through (the/ Purchasing Supervisor, (or this procurement.
77. Additionally, the RFP mandated that, in accordance with State of Texas
guidelines, to obtain the best value for the County through a negotiated procurement
Page 41 of 107
' .
process, "[a]ll information will be kept confidential until a contract is formally executed
or the RFP is cancelled."
78. Business Q submitted a bid for the RFP in late September 2010. Business
C submitted a competing bid that included Nealy's company, KNI, as a minority
subcontractor to provide "staffing and management support" for the contract. Nealy was
to receive approximately 30 percent of Business C's proposed $5 million bid. During the
bid evaluations, Business C was erroneously scored lower on its minority participation
than the minimum necessary to move forward in the RFP process. Thus, in November
2010, Business Q and three other vendors advanced forward in the RFP process, but
Business C and Nealy/KNI did not.
79. Dallas County invited Business Q and the other remaining bidders to
submit a BAFO for the RFP in December 2010. Soon after, during the no-contact period
of the RFP, Business Q signed an eight-day contract retaining Nealy from December 29,
2010 until January 5, 2011- the day after its BAFO was due- to "assist [Business Q]
relating to the Dallas County Request for Proposals ('RFP') of Desktop Support
Services." Nealy's $10,000 retainer was to be paid up front, and she billed Business Q
on the first day of her contract period.
80. In January 2011, Business C challenged its elimination from the RFP
process based on minority scoring. After the County corrected the error, it permitted
Business C to submit a late BAFO, which still included Nealy as a subcontractor and
which edged in lower than Business Q' s revised bid. Consequently, the previously-
Page 42 of 107
' .
scheduled vote to select a vendor, set for January 25, 2011, was pulled from the
Commissioners Court agenda and the selection process was delayed to permit an
evaluation of Business C's BAFO. Ultimately, Business Q was awarded the contract on
February 22, 2011.
arose that advanced Business Q' s and Business C' s interests, including:
a. Price made a motion and voted in favor of selecting Business Q as the
preferred Desktop Technical Support vendor with whom to begin contract negotiations in
February 2011.
b. Price made a motion and voted in favor of approving the Desktop
Technical Support contract between Dallas County and Business Q in February 2011.
The agreement with Business Q was a three-year contract worth approximately $3.6
million, with the option of two one-year extensions.
82. While Price publicly advocated for and sponsored Business Q in the above-
described manner, Price and Nealy conducted secret, concealed transactions to advance
Business Q's and Business C's interests and to unlawfully enrich themselves and others
known to the Grand Jury, conduct they hid and attempted to hide from Dallas County,
RFP selection committee members, the IT Steering Committee, members and employees
of the Commissioners Court, competing vendors, and Dallas County citizens. These
Page 43 of 107
a. During the no-contact period of the Desktop Technical Support RFP, and
before Business C submitted its joint BAFO with Nealy/KNI, Price leaked confidential
information to Nealy about the four finalists for the RFP by forwarding to Nealy an email
from the Commissioners Court's assistant administrator to the Commissioners that
contained the selection committee's evaluation scores, the four bidders' BAFO pricing,
minority subcontractor information, proposed transition times, and contract negotiation
requests. Subsequently, Business C/KNI submitted one of the lowest offers.
b. On the same day that a previously-proposed Commissioners Court order to
select Business Q as the Desktop Technical Support vendor was pulled from the Court's
January 25, 2011 agenda, Nealy deposited a $2,500 check from Business C.
c. Price continued to drive the 2005 BMW and the new 201 0 Avalanche, a
vehicle Price personally took delivery of from the dealership in the months leading up to
the issuance of the Desktop Technical Support RFP, while Nealy made car payments
totaling approximately $5,900 during the period of the Desktop Technical Support RFP
selection process.
d. Nealy spent approximately $8,800 on the four properties she bought for
e. During the period of the Desktop Technical Support RFP process, Nealy
paid Price approximately $9,525 in seven separate financial transactions. Nealy's stream
of benefits to Price included transactions during the RFP selection period, such as, for
example:
Page 44 of 107
(1) In the month following Business C and KNI's RFP bid, Nealy paid
Price $4,175.
(2) Three days after Business Q submitted its BAFO for the Desktop
Technical Support RFP, Nealy paid Price $2,100.
(3) Upon receiving Business Q's $10,000 check for her eight-day
consulting contract, Nealy made a car payment on the 2010 Avalanche and paid
the property taxes due for ***8 S. Lancaster Road and ***0 S. Lancaster Road.
Business H
83. Business H, a company known to the Grand Jury, conducted interstate and
international business, including in the Dallas Division of the Northern District of Texas.
84. In or about mid-2005, Dallas County's director of planning and zoning
briefed the Commissioners Court about the possibility of obtaining Foreign Trade Zone
status for properties located in Wilmer, Hutchins, Dallas, and Lancaster, Texas.
85. At that time, FTZ status had been granted previously for certain property in
Dallas County known as Foreign Trade Zone 39 or the Southport Foreign Trade Zone,
which was within the City of Dallas near the intersection of Interstate Highway 20 and
Interstate Highway 45. Interested developers sought an expansion ofFTZ 39 to include
their own properties located in Wilmer, Hutchins, Dallas, and Lancaster. Because of the
number of properties in different cities, a single, comprehensive application was
developed for these properties. The application identified the particular land for which
FTZ status was sought and was required to include consent letters from each potentially-
Page 45 of 107
impacted local taxing authority - such as cities, counties, and school districts -
expressing concurrence for the FTZ designation regarding each property.
86. The Dallas County Commissioners Court was one of the taxing authorities
whose consent by vote was necessary for the FTZ expansion. Such an expansion
constituted business, a transaction, or series of transactions of Dallas County involving a
thing of value of $5,000 or more.
87. After several. developers separately approached the DFW Airport Board
(the Board) about obtaining FTZ status for specific properties, the Board contacted Dallas
County to suggest that the County lead an effort to develop an application for a
comprehensive zone that would include the various individual properties in these
multiple cities.
88. Price agreed with the recommendation of the County's planning director in
March 2006 that the County should hold a public hearing during the Commissioners
Court's Aprilll, 2006 formal agenda to obtain input for the development of the
boundaries of a possible FTZ in the Lancaster-Wilmer-Hutchins-Southeastern Dallas area
and publish notice of the hearing in newspapers. The Court held the hearing as planned.
By September 2006, a proposed application for several properties had been prepared for
briefing to the Commissioners Court for consent and set on the DFW Airport Board
agenda for approval.
89. At that point, Business H decided to seek a late addition of its own property
in DeSoto, Texas to the then-completed application for FTZ designation. Business H,
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with Nealy already on retainer, paid Nealy until approximately March 2008 to lobby for
such a result. Price assisted Business H' s efforts in several ways, including delaying for
several months a Commissioners Court vote to grant consent for the existing application.
In or about late February 2008, approximately a year and a half after the initial
application was to be considered by the Commissioners Court, the FTZB approved FTZ
status for all of the properties in Dallas, Wilmer, Hutchins, and Lancaster, and Business
H's property in DeSoto.
arose that advanced Business H' s interests, including:
a. After Price met with Nealy and Business H executives in November 2006,
Price pulled from the Commissioners Court agenda an item recommending the
endorsement of the FTZ application as it then existed without Business H's property.
b. Price met with an attorney representing the DFW Airport Board and asked
what Business H needed to do to join the then-existing FTZ application as opposed to
making its own separate application.
c. Price continued to delay the Commissioners Court's discussion of the issue
and the approval of the FTZ application until approximately May 2007, allowing
Business H to try to obtain approvals from the appropriate taxing authorities for its own
FTZ request.
Page 47 of 107
d. Some of the delay between October 2006 and May 2007 was due to
Business H' s efforts to convince one or more Dallas City Council members to endorse
Business H' s property as part of the FTZ application. Price told one Councilman that if
the Councilman did not endorse the inclusion of Business H' s property in the existing
FTZ application, Price would not approve any FTZ application.
e. Price wrote letters to the Dallas Independent School District (DISD) and
the City of Dallas vouching for Business Hand urging their immediate support to include
Business H' s DeSoto property in the pending Dallas, Wilmer, Hutchins, and Lancaster
FTZ-expansion application.
f. In May 2007, the Commissioners Court considered a briefing that proposed
two separate applications for FTZ status: one for Business H's property and the other for
the Wilmer, Hutchins, Dallas, and Lancaster properties. Price voted "NO!" against
approving the separate applications.
91. While Price publicly advocated for and sponsored Business H in the above-
described manner, Price and Nealy conducted secret, concealed transactions to advance
Business H' s interests and to unlawfully enrich themselves and others known to the
Grand Jury, conduct they hid and attempted to hide from Dallas County, members and
employees of the Commissioners Court, applicants in the then-existing FTZ application
for Dallas, Wilmer, Hutchins, and Lancaster properties, the DFW Airport Board, the
FTZB, and Dallas County citizens. These transactions included the following acts,
among others:
Page 48 of 107
a. Price continued to drive the 2005 BMW and the 2007 Avalanche described
in paragraphs 33 and 34, while Nealy made car payments totaling approximately $42,000
during the period that Price advocated for Business H regarding its FTZ application.
b. Nealy spent approximately $51,000 on the four properties she bought for
c. During the span of Price's and Nealy's assistance to Business H regarding
the FTZ, Nealy paid Price approximately $73,000 in over 20 separate financial
transactions, many of which were checks Nealy wrote to Dallas Telco that Price
deposited or cashed in exchange for stacks of$100 bills. Nealy's stream of payments to
Price included the following examples:
(1) Approximately two weeks after Price's conversation with the Dallas
Councilman about approving Business H's property in the FTZ application, Nealy
paid Price $5,000.
(2) The day after Price voted "NO!" against the two proposed separate
applications for FTZ status with Business H's property in its own application,
Nealy paid Price $2,500, and she paid him another $2,500 two days later.
(3) Within the week after Price wrote letters to the DISD and the City of
Dallas urging their immediate support for including Business H' s DeSoto property
in the pending application, Nealy paid Price $4,000.
Page 49 of 107
D. CONCEALMENT OF THE CORRUPT AGREEMENT
92. Because (i) the conspiracy was ongoing, (ii) further action was required by
the Dallas County Commissioners Court concerning the matters sought by Nealy's and
Campbell's clients, and (iii) Price was a high-level public official at the time the corrupt
stream of payments and benefits were made, it was a necessary part of the agreement to
conceal the illegal payments and benefits Price received. Price, Nealy, and Campbell
took steps to conceal the corrupt agreement, including the following, among others:
a. Price, Nealy, and Campbell did not disclose Price's receipt of the illegal
benefits from Nealy to Dallas County, members and employees of the Commissioners
Court, Dallas County citizens, and others affected or influenced by Price's actions or
inactions described above such as, for example, RFP selection committee members, the
IT Steering Committee, competing vendors for various RFPs, applicants for FTZ status,
the DFW Airport Board, and the FTZB.
b. Price affirmatively concealed the illegal benefits he received from Nealy
by filing Personal Financial Statements, signed under oath, with Dallas County for the
reporting years 200 1 through 2008 and 2010 that intentionally omitted the illegal
payments, vehicles, and land purchases.
c. Nealy created false books and records to conceal the quantity and dollar
amount of payments she made to Price.
Page 50 of 107
Overt Acts
93. In furtherance of the conspiracy and to effect its objects and purposes, at
least one of the conspirators committed, and caused to be committed, one of the
following overt acts, among others, in the Dallas Division of the Northern District of
Texas, and elsewhere:
94. The Grand Jury realleges and incorporates by reference the acts identified
in paragraphs 31 to 92 as overt acts in furtherance of the conspiracy and to effect its
objects and purposes.
95. On numerous occasions during the calendar years 2001 through June 27,
2011, Nealy gave Price financial benefits totaling approximately $950,000.
96. Price omitted all of the payments and other financial benefits from Nealy
when he filed his state-law mandated Personal Financial Statements for the calendar
years 2002 through 2008 and 2010, which he signed under oath and filed with the Dallas
County Clerk on or about May 28, 2002, April 30, 2003, February 11, 2004, May 5,
2005, May 1, 2006, April 30, 2007, June 26, 2008, April 30, 2009, and May 2, 2011.
97. Price failed to file his state-law mandated 2009 Personal Financial
Statement with the Dallas County Clerk between April30, 2010, the due date of the
Statement, and June 27, 2011.
98. In mid-to-late December 2001, after Business S submitted a proposal for the
IT Outsourcing RFP, Nealy promised to assist Business S in advancing forward in the
RFP process.
Page 51 of 107
99. On or about January 2, 2002, Nealy paid Price $3,000 by causing a transfer
of the funds from her KLNA account ****8994 at City Bank to Price's account
****7407 at City Banlc
100. During the selection process for the IT Outsourcing RFP, on or about
January 11, 2002, Price provided Nealy with written answers to Business S's questions
concerning the RFP, including inside information about the lowest bidder.
101. On or about February 5, 2002, Price made a motion in Commissioners
Court and voted in favor of advancing Business S forward in the IT Outsourcing RFP
selection process, which allowed Business S to submit a presentation to the
Commissioners Court and a BAFO for the contract.
102. On or about March 20, 2002, Nealy helped facilitate the negotiation of the
terms of a subcontractor agreement for Business 0 with Business S for the IT
Outsourcing contract with Dallas County.
103. On or about Apri112, 2002, Nealy purchased for Price a parcel of real
property located in Canton, VanZandt County, Texas, for which she made a $28,819.63
payment at closing and fmanced the remaining $55,000 through City Bank in Forney,
Texas, the same bank where Price maintained his nominee account.
104. On or about April 30, 2002, Price made a motion in Commissioners Court
and voted in favor of selecting Business S as the preferred IT Outsourcing Services
vendor with whom to begin negotiations.
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105. On or about May 16, 2002, Nealy billed Business S $25,000 for
"Consulting Services" and "Success Fee- Dallas County."
106. On or about May 21,2002, Price made a motion in Commissioners Court
to approve the IT Services Master Agreement and fourteen Service Level Agreements
between Dallas County and Business S.
107. On or about May 21, 2002, Nealy paid Price $2,500 by transferring the
funds from her KLNA account ****8994 at City Bank to Price's nominee account
****6372 at City Bank.
108. On or about July 26,2002, Nealy purchased a 2002 Chevrolet Avalanche
that she provided to Price for his use.
109. On or about October 2, 2002, the UGSA Tax Collection system was used to
research the three Lancaster Road properties that Nealy later bought for Price. The
results of this search were located in Price's possession on June 27, 2011.
110. On or about October 22,2002, Campbell emailed Nealy and others with
Business S stating the importance of thoroughly briefing Nealy and Price in advance of
an upcoming Commissioners Court session in which the Commissioners were set to
"debate" on the County's contemplated integrated courts management system project.
111. On or about October 23, 2002, Price paid an individual known to the Grand
Jury $3,090 for the individual's work on Price's Canton property. Price paid the bill out
of the City Bank account he maintained in the nominee name of family member WFP.
Page 53 of 107
112. During the week of December 8, 2002, Nealy and Price met with a
Business S sales manager, after which meeting the sales manager emailed Nealy to
discuss Business S' s potential hiring of C.K.
113. On or about December 24, 2002, at approximately 9:29a.m., Nealy
withdrew $1,000 from her KLNA account ****8994 at City Bank, with "Cash (Price)''
written in the memo line. Approximately 31 seconds later, $1,000 currency was
deposited into Price's nominee City Bank account ****6372.
114. On or about January 9, 2003, Price signed a letter addressed "To Whom It
May Concern" commending Business S as "the most responsive, forthright and credible
in their approach" and that "[t]hey have proven to be a great partner and have
aggressively met the many challenges that will face any organization during the transition
period of this type of contract." Price elaborated:
I have found their staff and the staff of their subcontractors to be of

the highest caliber and they present an attitude of service first. I am
looking forward to the remaining months and years of our relationship with
[Business S] and I have full confidence that it will be a very successful
experience.
115. On or about February 5, 2003, at approximately 11:30 a.m., $1,000 was
withdrawn from Nealy's KLNA account ****8994 at City Bank. Approximately four
minutes later, $1,000 in currency was deposited into Price's nominee account ****6372
at City Bank.
116. On or about February 12, 2003, Nealy scheduled a meeting with Price and
Business S management.
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117. On or about March 3, 2003, Price faxed Nealy an internal Dallas County
document that detailed the current status of the County's IT projects and needs, budget
information, and recommendations about the County's potential courts management
system project and others that Business S was pursuing during the span of its consulting
contracts with Nealy.
118. Price signed a letter to a Business S executive dated March 4, 2003, the day
before Nealy was to meet with a Business S sales manager concerning renewing her
contract, in which Price told the executive, "I am duty bound to remind you that some
things have not changed." Price copied Nealy at the bottom of the letter via "cc" and had
a member of his staff fax Nealy the letter.
119. On or about March 5, 2003, Nealy paid Price $4,500 by split-depositing
two checks made payable to her in the total amount of $9,400 by depositing $4,500 into
Price's nominee City Bank account ****6372 and depositing the remaining $4,900 into
her KLNA account ****8994.
120. On or about March 27, 2003, Nealy signed a letter to the Business S sales
manager referencing their previous discussions about her contract's March 31, 2003
expiration date, renewal options, and the fact that a "final definitive agreement has not
been determined."
121. On or about March 28,2003, Campbell emailed Nealy and the owner of
Business Q the contact information for another Business S executive whom Business S
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had recently promoted to oversee company operations that included its contract in Dallas
County. Nealy printed the email and handwrote "To: JWP" at the top of the page.
122. On or about April 7, 2003, Nealy emailed the same Business S sales
manager with whom she met in December 2002 to ask about the status of hiring C.K.
123. On or about April27, 2003, Nealy signed a personal financial statement in
connection with her loan application to Lone Star Bank to purchase ***2 South Lancaster
Road, showing $468,015 in annual income.
124. On or about April28, 2003, Price signed a second letter to Business S,
addressed to the same executive for whom Campbell emailed Nealy the contact
information on March 28, 2003. In this letter, Price stated:
Based on recent discussions and information there may be some

deviation on some of the promises made in the outset of this venture. This
is a grave cause of concern and disappointment. Any variance from the
original plan would be a breach, and unacceptable.
Please ensure that all of the covenant and agreements that we have
made in this regard are being honored.
125. The day after Price's April28, 2003 letter, Nealy obtained a new contract
with Business S for a term retroactively starting April 1, 2003 and continuing through
December 31, 2003. The contract provided Nealy with monthly compensation of $5,000,
plus a $20,000 success fee if Business S was shortlisted as one of three IT outsourcing
vendors for Parkland Hospital and a $35,000 success fee for other new contracts valued
over $5 million in Dallas County and elsewhere.
Page 56 of 107
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126. On or about April28, 2003, Nealy paid Price $5,200 by transferring the
funds from her KLNA account ****8994 at City Bank into Price's nominee City Bank
account ****6372.
127. On or about May 5, 2003, at approximately 9:32 a.m., Nealy received a
Lone Star Bank loan commitment letter addressed to Nealy, advising her that it would
loan her up to $70,000 to be used at the Sheriff's auction scheduled the next day for ***2
S. Lancaster Road.
128. On or about May 5, 2003, at approximately 12:46 p.m., a CPA known to
the Grand Jury prepared for Price, at Price's request, a 10-year $70,000 loan repayment
schedule for ***2 S. Lancaster Road.
129. On or about May 6, 2003, Nealy purchased ***2 S. Lancaster Road at the
Sheriff's auction for $39,471.25.
130. On or about May 19,2003, Campbell emailed several Business S
employees, including the executive to whom Price sent the April 28, 2003 letter, stating
that Price "had concerns with" several issues, including Nealy's contract renewal and the
hiring of C.K., both of which Campbell noted had been resolved.
131. Campbell also relayed in the same May 19,2003 email that Price further
expected Business S to utilize a specific minority subcontractor, Business Q, not only in
Dallas County, but also in Lee County, Florida. Campbell noted that these issues were
still unresolved.
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132. On or about May 22, 2003, Price acquired property insurance policy
number SCP04070270 for ***2 Lancaster Road.
133. On or about May 23, 2003, Price and/or Nealy submitted a sealed bid to
the City of Dallas regarding the public sale of the foreclosed property located at ***0 S.
Lancaster Road. The sealed bid proposed a purchase price of$6,502.15 and included a
down payment (including a $20 deed recording fee) of$1,020.
134. On or about May 23,2003, Price withdrew $1,020 from his Dallas Telco
account.
135. Nealy's bid of $6,502.15 for ***0 S. Lancaster was the highest bid and
Nealy was notified of this on or about May 30, 2003.
136. On or about June 2, 2003, Nealy was substituted for Price as the owner of
***2 S. Lancaster Road on insurance policy number SCP04070270.
137. On or about June 17, 2003, Price seconded a motion in Commissioners
Court and voted to approve Business S to perform an Oracle upgrade assessment for the
County at a cost of approximately $200,000.
138. On or about August 5, 2003, the City of Dallas notified Nealy that she still
owed $5,502.15 on her bid related to ***0 S. Lancaster Road. Nealy remitted a
Cashier's Check for $5,502.15 to the City of Dallas and received the deed on or about
August 22, 2003.
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139. On or about August 7, 2003, Nealy as applicant and Price as co-applicant
signed an agreement for water and sewage services to be provided to the Canton
property.
140. On or about August 8, 2003, Price paid the initial fees for water and
sewage services for the Canton property with a check from his nominee account at City
Bank.
141. On or about October 16, 2003, in preparation for a conference call
scheduled the next day with Business S management to review Nealy's consulting
contracts, Campbell emailed Nealy to give her a list of "current initiatives" that Nealy
was "slated to be working."
142. On or about November 17, 2003, Nealy had a will prepared in which she
bequeathed to Price the properties located at ***2 S. Lancaster Road, Dallas, Texas;
Canton, Texas; and ***0 S. Lancaster Road, Dallas, Texas.
143. On or about December 16,2003, Price seconded a motion and voted to pay
Business S $21,125 for transition services and $3,932 monthly for equipment and
monitoring support while Business S finalized its sale of its IT assets to Business A and
negotiated with Dallas County to accept a change of control of the IT Outsourcing
contract from Business S to Business A.
144. On or about December 29, 2003, Nealy emailed a Business S sales
manager, informing him that she had not received any information about extending her
contract, due to expire on December 31, 2003.
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. .
145. On or about December 30,2003, Nealy paid Price $2,000 by check number
4924 issued from Nealy's KLNA account ****1364 at Bank of America.
146. On or about February 10, 2004, Nealy signed a consulting agreement for
$5,000 per month with Business S, effective January 1, 2004 through December 31, 2004,
promising to "leverage established contacts at Dallas County to assure that the Client
enjoys an excellent relationship throughout current contracts [sic] primary term." She
further agreed to assist in securing contracts for Business S regarding the County's
contemplated Oracle upgrade project, records management contract, systems integration
related to the planned Integrated Courts Management System, and the Juvenile
Information System, for which Nealy would earn a percentage of the total value of any
executed contract.
14 7. On or about March 31, 2004, Nealy faxed to Price a letter from Business A
to the County concerning several negotiation points related to terms under which
Business A was willing to assume Business S' s IT Outsourcing contract. On the fax cover
sheet to Price, Nealy wrote, "Please call."
148. On or about April19, 2004, Nealy partnered with Business Bin submitting
a proposal for the DCRIIS RFP for which Nealy was to provide "an outreach and
education program."
149. After writing a $2,000 check to Price's campaign on April21, 2004,
Campbell billed Business A for the $2,000, listing the amount on his expense report as
seminar/conference training.
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. .
150. On or about May 25, 2004, Price made a motion and voted in favor of
advancing Business B and three other vendors in the selection process for the DCRIIS
RFP.
151. Nealy paid Price $3,500 the next day.
152. Nealy noted on her calendar a meeting set for June 14, 2004 regarding
Business B, Business C, and Business L.
153. On or about June 15,2004, Price made a motion in Commissioners Court
to accept the change of control from Business S to Business A and to amend the IT
Outsourcing contract to reflect Business A as the vendor.
154. On or about June 16, 2004, Nealy negotiated the terms of a possible
$50,000 agreement with Business B to "sponsor a marketing program" for theDCRIIS
RFP.
155. Campbell billed Business A for "Client Entertainment & Meals" on June
17, 2004, listing Nealy and Price as the attendees.
156. On or about June 28,2004, Nealy paid Price $2,000 by check number 5150
issued from Nealy's KLNA account**** 1364 at Bank of America. The check was dated
the day before a meeting scheduled on Nealy's calendar for June 29, 2004 with Price and
Campbell regarding Business B.
157. On or about July 17,2004, Campbell paid Nealy $1,000 by check number
2512 issued from Campbell's personal account ****0526 at Bank of America.
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. .
158. On or about July 19,2004, Nealy paid Price $3,000 by check number 5151
issued from Nealy's KLNA account**** 1364 at Bank of America.
159. Campbell billed Business A for "Client Entertainment & Meals" on or
about July 21, 2004, listing Nealy and Price as the attendees.
160. Sometime prior to July 23, 2004, the exact date being unknown to the
Grand Jury, Nealy unsuccessfully attempted to obtain a tax bidder's certificate from
Dallas County so she could bid on ***8 S. Lancaster Road at a Sheriff's auction. On or
about August 2, 2004, since Nealy was unable to bid on the property, Price caused an
individual known to the Grand Jury to bid $6,600 for it at the Sheriff's auction.
161. On or about August 2, 2004, Nealy purchased official check number
251916067 from Lone Star Bank in the amount of$6,400. This official check made
payable to the Dallas County Sheriff was used by the known individual to acquire ***8
S. Lancaster Road property for Price.
162. On or about August 2, 2004, Campbell paid Kathy Nealy & Associates
$5,000 by check number 3206 issued from Campbell's personal account at Tinker
Federal Credit Union.
163. On or about August 3, 2004, a previously-scheduled order on the
Commissioners Court agenda to approve the selection committee's two recommended
vendors to move forward in the DCRIIS bidding process and exclude Business B was
pulled from the court's agenda.
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164. On or about August 3, 2004, Price voted in favor of authorizing the County
Judge to sign the novation agreement between Business A and Dallas County.
165. Campbell billed Business A for a meal with Nealy and Price on or about
August 9, 2004.
166. On or about August 9, 2004, Nealy paid Price $3,500 by check number
5167 issued from Nealy's KLNA account**** 1364 at Bank of America.
167. On or about August 10, 2004, Price convinced other Commissioners to
reject the DCRIIS selection committee's recommendation to eliminate Business B from
the RFP process. On Price's motion, the Commissioners Court voted to keep Business B
in the selection process and move forward with three other vendors for the DCRIIS RFP.
168. On or about that same day, Campbell submitted to Business B a $10,000
invoice dated August 10, 2004 for "Supplemental Consulting Services for Sales and
Business Development."
169. Nealy noted on her calendar a meeting set for August 13, 2004 between
Business B, Business C, Campbell, and a partner with Business L.
170. On or about August 17,2004, City Bank of Forney requested that Nealy
provide evidence that the 2003 real estate taxes for the Canton property had been paid.
Nealy faxed the correspondence to Price with a note that Nealy provided the evidence to
City Bank on or about August 23, 2004.
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171. On or about August 19, 2004, Campbell signed an amendment to his
contract with Business B, increasing Campbell's monthly pay to $10,000 for the months
of September and October 2004.
172. On or about August 26, 2004, Campbell paid Kathy Nealy & Associates
$7,500 by check number 1026 issued from Campbell's CCG account ****3066 at Bank
of America, with "BP Invoice" written in the check's memo line.
173. On or about August 27,2004, Nealy paid Price $2,500 by check number
174. Campbell billed Business A for meals with Nealy and Price on September
2 and September 4, 2004.
175. On or about September 15, 2004, Nealy handwrote on her calendar "Friday
AM- Breakfast -Hyatt Hotel," as well as "up front- $10K K" and "5K monthly," which
related to a scheduled meeting for September 17, 2004 with Campbell and Business B
managing director, H.T., at the Hyatt Regency.
176. Campbell emailed Nealy on or about September 21, 2004, requesting that
Nealy provide him with a $7,500 invoice for her efforts on the DCRIIS project for
Business B.
177. Nealy set a meeting on her calendar for October 18, 2004 with Price, a
Business A vice president of sales (known to the Grand Jury), Campbell, and herself.
178. On or about November 3, 2004, Campbell emailed Nealy a write-up of
work she allegedly performed for Business B the preceding month. Nealy copied
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<
Campbell's write-up into an activity report for herself that she attached to her $4,000
invoice to Business B for "Consulting Services- October 2004."
179. On or about November 4, 2004, Campbell signed a second amendment to
his contract with Business B, reverting Campbell's salary back to $5,000 per month
beginning November 6, 2004 until at least January 5, 2005.
180. On or about November 23,2004, Nealy purchased a new 2005 BMW that
she provided to Price for his use.
181. On or about December 6, 2004, Campbell emailed Nealy a write-up of
work she allegedly performed for Business B the preceding month. Nealy copied
Campbell's write-up into an activity report for herself that she attached to her $4,000
invoice to Business B for "Consulting Services -November 2004."
182. On or about December 31,2004, Nealy paid Price $4,000 by endorsing
check number 5397 payable to Kathy L. Nealy, issued from Nealy's KLNA account
**** 1364 at Bank of America.

183. On or about January 18, 2005, Nealy received and filed in her office a
Dallas County memo marked "Confidential- Not for Distribution," dated January 18,
2005 and issued by the DCRIIS selection committee to the Commissioners Court
concerning the committee's recommended vendor. Among other information, the memo
contained the committee's scoring summary of the four finalists' bids and each of their
BAFO pricing, including Business B.
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184. On or about that same day, January 18, 2005, Nealy paid Price $1,000 by
check number 5424 issued from Nealy's KLNA account ****1364 at Bank of America.
185. On or about January 25, 2005, Price voted in favor of approving Business
B as the selected DCRIIS vendor and authorizing the County to begin contract
negotiations with Business B.
186. In the same Commissioners Court session on or about January 25, 2005,
Price voted in favor of advancing Business B in association with Business C to the next
phase of the RFP process for the Countywide Receipting System RFP.
187. On or about February 1, 2005, Nealy billed Business A $9,237.02 for
commissions on Dallas County projects such as the Oracle upgrade.
188. On or about February 22, 2005, Nealy signed a "Government Affairs
Consulting Agreement" with Business Bin which Nealy promised to provide services
related to "bid-winning methods" and "strategies concerning the Texas Metropolitan
Local Government," among other things, in exchange for a $4,000 monthly fee.
189. On or about March 9, 2005, during the Countywide Receipting System
RFP, Price faxed to Nealy an internal memo that the County's purchasing agent had
provided to the IT Steering Committee, relaying that the evaluation committee
recommended not advancing Business Bin the RFP process. Price's fax also included
the evaluation committee's scores of each competing vendor and the dollar figures of
their bids.
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190. On or about March 17,2005, Nealy and/or Price directed the known
individual who bid on ***8 S. Lancaster Road to issue a Quit Claim Deed to Nealy.
Price served as the Notary Public for this real estate transaction.
191. On or about March 28, 2005, Nealy paid Price $1,000 by check number
5497 issued from Nealy's KLNA account**** 1364 at Bank of America.
192. On or about March 29, 2005, Price voted in favor of having the County
Judge execute a contract with Business B for the DCRIIS project.
193. On or about April26, 2005, Price met with Nealy and shared inside
information concerning Business A.
194. On or about July 26, 2005, Nealy signed a "Marketing Agreement" with
Business B for payment not to exceed $50,000 to Nealy, in exchange for Nealy's promise
to identify title companies to which Business B could market real property records
imaged as part of its DCRIIS contract in Dallas County.
195. On or about August 19, 2005, Nealy faxed to Business A a confidential,
internal Dallas County memo dated August 12,2005, addressed to the County's CIO,
concerning Business A's performance of its contract with Dallas County.
196. On or about September 9, 2005, Nealy paid Price $1,000 by check number
5742 payable to Kathy L. Nealy, issued from Nealy's KLNA account ****1364 at Bank
of America, with "Salary" written in the check's memo line.
197. On or about January 5, 2006, Nealy faxed to Campbell an internal Dallas
County document dated December 6, 2005 and entitled "IT Priorities," which relayed
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information about current County IT projects, reorganization of the IT department, and
upcoming projects contemplated by the County, among other things.
198. On or about January 8, 2006, Nealy signed another "Government Affairs
Consulting Contract" with Business B for the period of January 1, 2006 to December 31,
2006, providing her with a $4,000 monthly fee.
199. On or about January 24, 2006, Nealy set an appointment on her calendar to
deliver a packet to Price's office concerning Business B.
200. On or about January 27, 2006, Nealy paid Price $4,500 by check number
201. Nealy entered the notation, "[Business A]- Chris Campbell update" on her
calendar for February 13, 2006.
202. Nealy set a meeting on her calendar for March 14,2006 with Campbell
"re: Dallas County."
203. On or about March 28, 2006, Nealy faxed to Price an email between
Campbell and Business A employees regarding "talking points" for a meeting with Price
that day. On the fax cover sheet, Nealy handwrote a thank you note to Price for agreeing
to meet with Business A.
204. On or about April12, 2006, Campbell paid Nealy $1,000 by check number
2848 from Campbell's personal account at Bank of America.
205. Nealy scheduled a meeting with Price regarding Business A for April13,
2006.
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206. Nealy scheduled another meeting with Price for April17, 2006, noting on
her calendar, "[Business A] - JWP follow-up."
207. On or about April17, 2006, Nealy paid Price $4,500 by check number
6171 payable to Dallas Tel-Co, issued from Nealy's KLNA account**** 1364 at Bank of
America.
208. On or about April29, 2006, Nealy applied for GMAC Smart Buy financing
for a 2007 Chevrolet Avalanche that she provided to Price for his use. Nealy made a
down payment of $4,849.17 and financed the remainder at $669.05 per month for 48
months, with a $21,268 balloon payment due at the end of the term.
209. On or about June 27, 2006, Price had a staff member fax and email to
Nealy a letter from Business A to Dallas County summarizing a detailed IT discussion
between the County's CIO, Price, another County commissioner, the County's
administrator, and several Business A executives and managers on June 22, 2006.
210. On or about June 30,2006, Price agreed to meet with Nealy about her
client, Business H, regarding Inland Port concerns.
211. On or about July 12,2006, Campbell paid Nealy $1,000 by check number
2942 issued from Campbell's personal account at Bank of America.
212. On or about July 13, 2006, Campbell emailed Nealy requesting a meeting
with Price related to a disputed issue involving Business A and the County.
213. Nealy arranged a meeting with Price, Campbell, and Business A
representatives for on or about July 18, 2006.
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.. Case 3:14-cr-00293-M Document 1 Filed 07/23/14 Page 70 of 109 PageID 70
214. On or about September 27,2006, Price removed from an October 2006
Commissioners Court agenda an item concerning the approval of the then-existing FTZ
application for Wilmer, Hutchins, Dallas, and Lancaster properties.
215. On or about September 27,2006, Price requested that the DFW Airport
Board remove from its October 2006 agenda the then-existing FTZ expansion application
for properties in Wilmer, Hutchins, Dallas, and Lancaster.
216. On or about October 11, 2006, Price leaked a confidential, internal Dallas
County document to Nealy via fax that discussed Business A's personnel and salaries
with respect to phasing out Business A's Dallas County contract.
217. On or about November 6, 2006, Nealy signed a one-year contract with
Business V for "consulting services" beginning November 2, 2006, to "make
introductions," "attend meetings," and "lobby on behalf of [Business VJ" in Dallas

County and other local venues, in exchange for a $2,000 monthly fee and 20% of the net
hourly margin for new business generated.
218. On or about November 13, 2006, Price faxed to Nealy an October 31,2006
memo from the Dallas County Director of Planning & Development to the
Commissioners Court recommending that the Court endorse the then-existing proposal to
expand the FTZ in southern Dallas County.
219. On or about November 13,2006, after receiving the memo from Price,
Nealy faxed it to a Business H executive.
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..
220. On or about November 14, 2006, Price contacted a senior level executive
with Business B and requested that H. T. be made "MD [managing director] on the
engagement" for the DCRIIS project.
221. On or about November 14,2006, Nealy scheduled a meeting with Price to
update him regarding the possible inclusion of Business H' s property in the FTZ
application.
222. On or about November 14,2006, Nealy forwarded to Price an email from
Business H advocating inclusion of its DeSoto property in the then-existing FTZ
application, despite any delay in the process that such inclusion might cause.
223. On or about November 20, 2006, during a meeting with Business H
executives, Price agreed to pull the FTZ application approval from the Commissioners
Court agenda set for the following day.
224. On or about November 21, 2006, Price met with an attorney representing
the DFW Airport Board and asked about the process for adding landowners to then-
existing FTZ application.
225. On or about December 12,2006, Price told a Dallas City Councilman that
if the Councilman did not endorse the inclusion of Business H' s property in the FTZ
application, Price would not approve any FTZ application.
226. On or about December 27,2006, Nealy paid Price $5,000 by endorsing a
$5,000 commercial check from a business known to the Grand Jury, payable to KLNA,
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..
which Price co-endorsed and deposited into his account ****1984 at Lakeside National.
Bank, withdrawing $3,000 in cash from such funds at the time of the deposit.
227. On or about January 16, 2007, Nealy noted on her calendar "JWP- $."
228. On or about January 17,2007, Nealy set an appointment on her calendar
with a Business H representative and Price to update Price concerning the FTZ.
229. On or about January 24, 2007, Price requested that an individual
representing the DFW Airport Board write a letter confirming the likelihood that FTZ
status would be readily available for a property in Price's district that was not part of the
current proposed FTZ expansion in southern Dallas County.
230. On or about February 26,2007, Nealy had a task on her calendar to
schedule a meeting with Price concerning Business V.
231. On or about February 26, 2007, Nealy had a task on her calendar to
schedule a meeting with Price concerning Business B and the Dallas County Clerk.
232. On or about March 26, 2007, Nealy paid Price $5,000 by check number
112 issued from Nealy's KLNA account ****2342 at Morgan Stanley.
233. On or about April 9, 2007, Nealy emailed Business H to advise that Dallas
County was still "on hold" regarding the FTZ application.
234. Nealy made a note to schedule a meeting on her calendar with Price and
the owner of Business Vfor April12, 2007.
235. On or about April27, 2007, Nealy notified Business Hthat Price
convinced at least two other members of the Commissioners Court to vote in favor of
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' .
including Business H' s DeSoto property in then-existing proposed FTZ application for
properties in Dallas, Hutchins, Wilmer, and Lancaster, rather than proceeding forward
with a separate FTZ application for Business H.
236. On or about May 1, 2007, consistent with Price's advocacy for a single
FTZ application that included Business H's DeSoto property, Price voted "NO!" against
two Commissioners Court orders that endorsed (1) a proposed expansion of the Southport
FTZ with the Dallas, Hutchins, Wilmer, and Lancaster properties, and (2) a separate
expansion of the Southport FTZ with Business H's DeSoto property.
237. Price signed a letter dated May 8, 2007 to the DISD Superintendent,
":ouching for Business .Hand urging DISD to "immediately support the addition of
[Business H's] DeSoto property to the Southport Foreign Trade Zone" application that
included the Dallas, Lancaster, Wilmer, and Hutchins properties.
238. Price also signed a letter dated May 8, 2007 to the Dallas City Manager,
likewise vouching for Business Hand urging the City of Dallas to "immediately support
the addition of [Business H's] DeSoto property to the Southport Foreign Trade Zone"
application that included the Dallas, Lancaster, Wilmer, and Hutchins properties.
239. On or about May 9, 2007, Price signed a letter to the DISD Board
President, vouching for Business Hand urging DISD to "immediately support the
addition of [Business H' s] DeSoto property to the Southport Foreign Trade Zone"
application that included the Dallas, Lancaster, Wilmer, and Hutchins properties.
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240. On or about May 15, 2007, Nealy handwrote "JWP ->Thanks!!" on an
email directed to Nealy from a Business H executive that praised Nealy's efforts
concerning the FTZ matter and stated, "whatever you are doing is certainly working for
us," in that (1) DISD and the City of Dallas appeared likely to approve Business H's
inclusion in the Dallas, Wilmer, Hutchins, and Lancaster FTZ application, and (2) the
DFW Airport Board decided to hold this application for a month to permit Business H to
obtain such approval.
241. On or about May 17, Nealy paid Price $4,000 by check number 9141
issued from Nealy's personal account ****3409 at Bank of America.
242. On or about May 21, 2007, Nealy faxed to a Business H executive the
letters Price had written to the DISD and the City of Dallas requesting immediate support
for the addition of Business H' s DeSoto property to the then-existing FTZ expansion
application.
243. On or about July 23,2007, Nealy faxed Business V's owner an internal
Dallas County memo from the County's purchasing supervisor to the Commissioners
Court, dated July 24, 2007, recommending that Business U and three others advance in
the Inmate Phone System RFQ process.
244. On or about July 31, 2007, Price seconded a motion and voted in favor of
advancing Business U and three others to advance in the RFQ process for the Inmate
Phone System contract.
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245. On or about August 1, 2007, Campbell entered into a six-month agreement
with Business A under which Business A paid Campbell a $5,000 monthly fee to serve as
a sales executive.
246. On or about September 10, 2007, a few days after Business V's owner
emailed Nealy for inside intelligence and help influencing the Desktop Support RFP on
behalf of Business U, Nealy paid Price $5,000 by check number 122 payable to Dal-
Telco, issued from Nealy's KLNA account ****2342 at Morgan Stanley.
24 7. On or about September 18, 2007, Price voted in Commissioners Court to
advance Business Uto the next stage of the Desktop Technical Support RFP.
248. On or about September 18,2007, Price forwarded to Nealy an internal
Dallas County memo discussing Business B and whether to exempt a proposed contract
from the bidding process.
249. On or about October 2, 2007, Nealy billed Business V$2,000 for
"Consulting Services- Dallas County" during September 2007, listing "Served as liaison
between client and Dallas County Commissioner John Wiley Price" as one of the services
she provided.
250. On or about October 29, 2007, Price forwarded to Nealy an email from the
County's purchasing agent to Price expressing concerns about an issue that the agent felt
had not been addressed by Business U regarding its bid for the Desktop Technical
Support RFP.
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251. On or about October 30, 2007, Nealy received a confidential, internal
Dallas County memo to the Commissioners Court dated that same day entitled,
"Additional Information on Award Recommendation," in which the County's purchasing
agent compared Business U' s and Business C' s BAFOs, including pricing, negotiation
points, and minority subcontractor participation for the Desktop Technical Support RFP.
252. On or about October 31,2007, Price had a staff member forward an email
to the County's CIO that attached a letter from Business Uto Price. In the letter,
Business U responded point-by-point to the confidential, internal Award
Recommendation memo that Nealy had filed among her records.
253. On or about November 2, 2007, Nealy billed Business V$2,000 for
consulting services in October 2007, listing "Provided client with updates re: [Business
U] & Dallas County" as part of her services.
254. On November 5, 2007, during the no-contact period of the Desktop
Technical Support RFP, Price leaked confidential information to Nealy about Business C
by forwarding to Nealy an internal Dallas County email from the County's purchasing
agent that contained financial information about Business C that Price had requested in
the Commissioners Court session one week prior.
255. Price sent a second email to Nealy on or about November 5, 2007,
containing confidential information about the County CI 0' s and County purchasing
agent's analysis of and response to Business U's October 31, 2007 letter to Price.
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256. On or about November 6, 2007, Price voted to approve and have the
County Judge execute an amendment to Business B's DCRIIS contract with Dallas
County that provided for additional services by Business B and payment for such
services.
257. On or about November 6, 2007, Price voted "NO!" against authorizing
contract negotiations with Business Cas the selected vendor for the Desktop Technical
Support RFP.
258. On November 7, 2007, Price leaked confidential information to Nealy
about Business C by forwarding to Nealy an internal Dallas County email discussing
fmancial information of Business C, including its payroll, insurance costs, income and
assets, and property tax payments.
259. On or about November 15,2007, Nealy paid Price $1,000 by check
number 9226 issued from Nealy's personal account ****3409 at Bank of America.
260. On or about November 16,2007, Nealy paid Price $1,000 by check
number 9227 issued from Nealy's personal account ****3409 at Bank of America
261. On or about November 25, 2007, during the no-contact period of the
Desktop Technical Support RFP, Price leaked sensitive, inside information to Nealy
about Business C by forwarding to Nealy an internal County email chain between the
County's CIO and the County's purchasing director in which they discussed potential
negotiation points and revisions to the County's proposed contract with Business C. In
the email chain, a County employee noted that "[a]t Commissioner Price's request I have
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added him to the distribution of this response." The email Price forwarded to Nealy also
included a copy of the proposed contract with Business C.
262. On or about November 26,2007, Nealy forwarded to Business Vthe
confidential email chain that Price sent to Nealy on November 25, 2007, including the
proposed contract with Business C.
263. On or about November 27,2007, Price voted "NO!" against awarding the
Desktop Technical Support RFP to Business C and against authorizing the County Judge
to sign the contract with Business C.
264. On or about December 28,2007, Nealy paid Price $2,500 by check number
7234 payable to Dallas Telco, issued from Nealy's KLNA account ****1364 at Bank of
America.
265. On or about February 22, 2008, during the no-contact period of the Inmate
Phone System RFQ, Price agreed to meet with representatives from Business U on
March 5, 2008.
266. On or about February 25,2008, Nealy emailed a Business H executive,
requesting information as to Business H' s property in the proposed FTZ expansion so that
Price could update the citizens of DeSoto at a town hall meeting the following evening.
267. On or about February 26, 2008, Price presented an update regarding
Business H' s FTZ status at the DeSoto town hall meeting.
268. On or about February 27,2008, Nealy paid Price $2,500 by check number
131 issued from Nealy's KLNA account ****2342 at Morgan Stanley.
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269. On or about March 7, 2008, during the no-contact period of the Inmate
Phone System RFQ, Price agreed to meet with Business U representatives and Nealy at
lunchtime on March 13, 2008.
270. On or about March 25, 2008, Price seconded a motion and voted in favor
of selecting Business U as the vendor for the Inmate Phone System RFQ and entering
into contract negotiations with Business U.
271. While negotiations were ongoing with Business U for the Inmate Phone
System contract and during the no-contact period, Price met with Nealy and an executive
with Business U on or about March 31, 2008.
272. On or about Apri12, 2008, Nealy billed Business V$2,000 for March 2008
consulting services, identifying a meeting she attended with Price and Business U
representatives as part of her services.
273. On or about June 6, 2008, Nealy paid Price $1,000 by check number 7440
issued from Nealy's KLNA account**** 1364 at Bank of America.
274. On or about June 17, 2008, Price made a motion and voted in favor of
awarding the Inmate Phone System contract to Business U and authorizing the County
Judge to sign a five-year contract estimated to generate approximately $6 million in
commissions for the County.
275. On or about July 31, 2008, Nealy completed a consultant questionnaire for
Business U in which she proposed to provide "business development consulting," to
serve as a "liaison between" Business U and local municipalities, and to serve as an
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"employee placement agency." In response to whether she or any member of her firm
had "any relationship to a government agency or instrumentality, a political party or
official thereof, or a candidate for political office," Nealy listed only a national political
party, not Price.
276. On or about August 6, 2008, Nealy received an email attaching a scope of
work document from Business U that proposed monthly payments of $5,500 for a three-
month period. Business U ultimately decided not to execute this document.
277. On or about December 22, 2008, Price endorsed the back of a check issued
by Business T, payable to John Wiley Price in the amount of $1,100, and cashed it on his
Dallas Telco account**** 1862, receiving eleven $100 bills.
278. On or about August 2, 2009, Nealy paid Price $750 by check number 1071
payable to [K.M.], an individual associated with Business M and known to the Grand
Jury. The check was issued from Nealy's Discover credit card account ****7391 and
had "Artwork- Bal. due $750" written in the check's memo line.
279. On or about May 10, 2010, Price took delivery of a 2010 Avalanche from a
Chevrolet dealership in Dallas.
280. On or about May 12,2010, Nealy signed financing documents on the 2010
Avalanche that Price had picked up two days earlier. Nealy added the $1,005 tum-in fee
for the 2007 Avalanche to the purchase price of the 2010 Avalanche, resulting in a total
purchase price of$39,937.53, which she financed for 72 months at $687.85 per month.
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281. On or about August 2, 2010, Nealy signed a six-month contract with
Business L to provide "advice to [Business L] concerning [Business L's] present and
potential clients," among other things, in exchange for a $7,500 monthly fee.
282. On or about September 30, 2010, Nealy partnered with Business C to
submit a bid for the Desktop Technical Support RFP No. 2010-090-5232, with Nealy's
company, KNI, as a minority subcontractor. Nealy's anticipated piece of the bid was
approximately 30 percent of Business C' s $5 million proposal.
283. On or about November 8, 2010, Campbell billed Business A for a meeting
with Price concerning a matter under the Commissioners Court's purview.
284. On or about December 21, 2010, Campbell billed Business A for a meeting
he attended with representatives of Business L.
285. When KNI and Business C failed to move forward in the Desktop
Technical Support RFP process, on or about December 29, 2010, Nealy signed an eight-
day, $10,000 contract with Business Q to assist it with its BAFO due January 4, 2011.
286. On or about January 3, 2011, after receiving Business Q's $10,000
payment, Nealy paid (1) the Dallas County Tax Assessor/Collector for the property taxes
on ***8 S. Lancaster Road and ***0 S. Lancaster Road from her KLNA account
****1364 at Bank of America, and (2) the car payment for the 2010 Avalanche.
287. On or before January 4, 2011, Nealy advised Business Q as to the dollar
range to target for Business Q's BAFO.
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288. On or about January 7, 2011, Nealy paid Price $2,100 by check number
9649 issued from Nealy's personal account ****3409 at Bank of America.
289. On or about January 11, 2011, Price signed a recommendation letter on
behalf of Business L addressed to the chief procurement officer of the City of Atlanta,
Georgia. In the letter, Price noted that Business L had submitted a proposal for financial
collection services to Atlanta, and he highly recommended Business L and its managing
partner for such services.
290. On or about January 15, 2011, during the no-contact period of the Desktop
Technical Support RFP, and before Business C submitted its joint BAFO with
Nealy/KNI, Price leaked confidential information to Nealy about the four finalists for the
RFP by forwarding to Nealy an email from the Commissioners Court's assistant
administrator to the Commissioners that contained the selection committee's evaluation
scores, the four bidders' BAFO pricing, minority subcontractor information, proposed
transition times, and contract negotiation requests. Subsequently, Business C/KNI
submitted one of the lowest BAFOs.
291. On or about January 25, 2011, when a previously-proposed Commissioner
Court order to select a Desktop Technical Support RFP vendor was pulled from the
Court's agenda to permit an evaluation of Business C's BAFO, Nealy deposited a $2,500
check from Business C.
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292. On or about February 8, 2011, Price made a motion and voted in favor of
entering into contract negotiations with Business Q as the selected vendor for the Desktop
Technical Support RFP.
293. On or about February 22, 2011, Price made a motion and voted in favor of
awarding the Desktop Technical Support RFP to Business Q and authorizing the County
Judge to execute a three-year contract worth approximately $3.6 million, with the option
of two one-year extensions.
294. On or about April22, 2011, Nealy paid Price $5,000 by endorsing check
number 2552 payable to Kathy L. Nealy, issued from Nealy's KLNA "campaign"
account ****3080 at Bank of America.
295. On or about May 6, 2011, Nealy paid Price $1,000 by check number 9679
issued from Nealy's personal account ****3409 at Bank of America.
296. On or about June 27, 2011, Price maintained approximately $229,500 in a
safe in his residence.
All in violation of 18 U.S.C. 371 (18 U.S.C. 666(a)(1)(B) and (a)(2)).
Page 83 of 107
Counts Two through Seven

Deprivation of Honest Services by Mail Fraud and Aiding and Abetting
(Violation of 18 U.S.C. 1341, 1346, and 2)
297. The Grand Jury hereby adopts, realleges and incorporates by reference the
allegations set forth in paragraphs one through twenty-three of this indictment as if fully
set forth herein.
298. At all times relevant to this indictment, Dallas County, Texas and its
citizens had an intangible right to the honest services of their public officials. As a public
official for Dallas County, Texas, John Wiley Price, the defendant, owed a fiduciary
duty to Dallas County and its citizens and was prohibited by state law from soliciting and
accepting bribes as consideration for his decision, opinion, recommendation, vote, or
other exercise of discretion as a public servant or for violating a duty imposed by law on
him as a public servant, duties explained in paragraphs six and seven of the Introduction
of this indictment.
The Scheme
299. Beginning in or about January 2001, the exact date being unknown to the
Grand Jury, and continuing through on or about June 27, 2011, in the Dallas Division of
the Northern District of Texas, defendants, John Wiley Price and Kathy Louise Nealy,
aided and abetted by each other and by others known and unknown to the Grand Jury,
engaged in mail fraud, that is, they devised a scheme and artifice to defraud and deprive
Dallas County and its citizens of their right to the honest and faithful services of
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Commissioner John Wiley Price through the solicitation and payment of bribes and the
concealment of material information.
Purpose of the Scheme
300. The purpose of the scheme and artifice was for Price to secretly use his
official position to enrich himself by soliciting and accepting payments and other things
of value from Nealy in the form of a stream of financial benefits, as consideration for
Price's action or inaction and influence with respect to contracts and other matters before
the Dallas County Commissioners Court, as specific opportunities arose, and for Nealy to
enrich herself by obtaining favorable action or inaction and influence for herself and her
clients through corrupt means.
Manner and Means
301. The scheme and artifice was carried out in the following manner and
means, among others: (a) Price solicited and accepted a stream of financial benefits in
the form of payments and other things of value, including real estate and vehicles, from
Nealy totaling more than $950,000; (b) Price provided favorable action or inaction and
influence on behalf of Nealy and Nealy's clients as requested and as opportunities arose;
and (c) Price and Nealy took steps to hide, conceal, and cover up this activity and the
nature and scope of their dealings with one another.
302. The manner and means of the defendants' scheme and artifice are more
fully described in paragraphs 31 through 92 and 95 through 296 of this indictment, which
are realleged and incorporated herein by reference.
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Execution of the Scheme
303. For the purpose of executing and attempting to execute the above-described
scheme and artifice to defraud, defendants Price and Nealy knowingly caused matters
and things to be delivered by the United States Postal Service and by private and
commercial interstate carriers according to the directions thereon, on or about the dates in
each count below:
Date Mailed
Count Contents
(on or about)
KLNA check number 8001 in the amount of$1,558.87
Two October 2, 2009 issued from Nealy's KLNA account**** 1364 at Bank of
America for a BMW monthly car payment
KLNA check number 8060 in the amount of$1,632.75
Three November 23,2009 issued from Nealy's KLNA account **** 1364 at Bank of
America for a BMW monthly car payment
KLNA check number 8255 in the amount of$687.85 issued
Four July 1, 2010 from Nealy's KLNA account ****1364 at Bank of America
for a Chevrolet Avalanche monthly vehicle payment
KLNA check number 8274 in the amount of$687.85 issued
Five July 16, 2010 from Nealy's KLNA account ****1364 at Bank of America
KLNA check number 8356 in the amount of $756.63 issued
Six November 1, 2010 from Nealy's KLNA account**** 1364 at Bank of America
KLNA check number 8387 in the amount of $687.85 issued
Severt December 10, 2010 from Nealy's KLNA account ****1364 at Bank of America
Each in violation of 18 U.S.C. 1341, 1346, and 2.
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Count Eight
Conspiracy to Defraud the Internal Revenue Service
(Violation of 18 U.S.C. 371)
304. The Grand Jury hereby adopts, realleges, and incorporates by reference the
allegations set forth in paragraphs 1 through 303 of this indictment as if fully set forth
herein.
305. The Internal Revenue Service (IRS) is an agency of the United States
Department of Treasury responsible for enforcing and administering the tax laws of the
United States and collecting taxes owed to the Treasury of the United States.
306. Defendants John Wiley Price, Kathy Louise Nealy, and Dapheny Elaine
Fain were residents and citizens of the United States and resided in the Northern District
of Texas during the time period set forth in this Indictment.
The Conspiracy and Its Objects
307. Beginning in or about October 2001, the exact date being unknown to the
Grand Jury, and continuing through on or about June 27, 2011, in the Dallas Division of
the Northern District of Texas, defendants, John Wiley Price, Kathy Louise Nealy, and
Dapheny Elaine Fain did knowingly combine, conspire, confederate and agree with
each other, and with others known and unknown to the Grand Jury, to defraud the United
States for the purpose of impeding, impairing, obstructing, and defeating the lawful
government functions of the Internal Revenue Service of the Treasury Department in the
ascertainment, computation, assessment, and collection of the revenue: to wit, income
taxes for the calendar tax years 2002 through 2009.
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308. It was further a purpose and object of the conspiracy to unlawfully conceal
and disguise approximately $1,150,000 in bribes and other taxable income that Price
received from several sources, including Fain, Male Man Sales d/b/a MMS, Nealy,
Kathy L. Nealy and Associates, KNI, Inc., Business M, and Business T.
Manner and Means of the Conspiracy
309. The conspirators used the following manner and means, among others, to
carry out the objectives of the conspiracy:
A. MALE MAN SALES (MMS)
310. Male Man Sales, d/b/a MMS Company (MMS), was an unincorporated
proprietorship with its principal office located in Dallas County, in the Northern District
of Texas. Fain filed an assumed name certificate for MMS in Dallas County in 2003,
identifying the business as a proprietorship. MMS originally sold novelty items and
clothing. In 2005, Fain renamed Male Man Sales the "MMS Company" at the request of
Business X (a company known to the Grand Jury) when Male Man began filling orders
for Business X and others for logo-stamped items, appliances, electronics, and other
goods.
311. Price co-owned and/or operated MMS with Fain and had use of MMS
company credit cards. He received approximately $133,925 from MMS but reported
none of this income on his tax returns. Price and Fain concealed Price's receipt of this
income by several means, including: (1) Fain endorsed and diverted third-party checks
to Price; (2) Price or Fain split the deposits of the third-party checks between an MMS
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account and one of Price's personal accounts; and (3) Price took cash back from deposits
into MMS accounts.
B. BRIBERY INCOME
312. As described in the Introduction and Counts 1 through 7 of this indictment,
realleged and incorporated herein by reference, Nealy paid Price a stream of financial
benefits totaling approximately $950,000 that included money, cars, and land. This
stream of benefits from Nealy to Price also included more than $90,000 in rental income
from Business T, a tenant located at one of the properties. Price reported none of this
income on his tax returns.
313. Nealy and Price concealed Nealy's bribery payments in the same manner
that Price and Fain hid Price's MMS income: (1) Nealy endorsed and diverted third-
party checks to Price; (2) Price or Nealy split the deposits of third-party checks between
Nealy's and Price's accounts; and (3) Price took cash back from deposits into Nealy's
accounts. Nealy also wrote checks payable to Price's fmancial institutions and checks
payable directly to Price on which she often wrote notations in the memo lines casting
the check as something other than income to Price. Additionally, Nealy wrote checks
payable to herself, endorsed them, and gave them to Price, which he deposited or cashed
at various financial institutions, and Nealy transferred money from her accounts to
Price's accounts.
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C. LAND PURCHASES
314. Nealy and Fain helped Price conceal income, assets, and expenditures
from the IRS by having parcels of real property titled in Nealy's and Fain's names.
Specifically, as described in Count 1 of this indictment, realleged and incorporated herein
by reference, Nealy paid for, and acted as the nominee owner of, four parcels of real
property that actually belonged to Price. Price did not report on his tax returns any
amounts that Nealy paid for the purchases, property taxes, and insurance for the four
properties.
315. Fain served as nominee purchaser and owner of three additional parcels of
real property for Price to conceal and disguise his ownership and receipt of income.
D. PRICELESS COLLECTION AND BUSINESS M
316. Price earned at least $50,000 from selling African art from his residence, at
Business T, and at Business M, where he maintained inventory on a consignment basis,
including art that he named and advertised as the "John Wiley Priceless Collection" or
"Priceless Collection." Price reported none of this income on his tax returns.
317. Price stored art pieces at MMS as well. He filed an assumed name
certificate for Priceless Collections in Dallas County, Texas in January 2003, identifying
the business as a proprietorship. He paid over $280,000 in cash and wrote at least five
checks from his nominee account at City Bank to buy inventory. Price also used
campaign funds to buy pieces that he sold through Business M and then deposited the
income earned on those sales into his personal accounts.
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E. BANKING PRACTICES
318. To facilitate the covert transfers of money from Nealy and Fain, and to
conceal the substantial sums of income paid to Price by Nealy, Fain, MMS, and
additional sources, Price, Nealy, and Fain opened numerous bank accounts at the same
financial institutions. Additionally, Price used his nominee account at City Bank to
negotiate payments from Nealy. The financial institutions associated with the defendants
included, among others:
a. City Bank in Forney, Texas
Price: Nealy: Fain:
Account****6372 Account****4654 Account ****3231

(held in nominee Account ****8994
name of family member)
Account ****7407
Account ****8751
b. Lakeside National Bank in Rockwall, Texas
Price: Fain:
Account * *** 1984 Account ****0007 (MMS)

Account ****2034
Account ****2042
Account ****2611
Account ****2985
c. Dallas Telco
Price: Fain:
Account ****1862 Account ****3476

Account ****0235 (MMS)
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d. Bank of America
Price: Nealy: Fain:
Account ****7956 Account ****1364 Account ****3413

Account ****3080 Account ****0955 (MMS)
Account ****6758
Account ****8122
Account ****9248
F. FALSE AND FRAUDULENT TAX RETURNS
319. Price, .Nealy, and Fain each presented false records to the same tax
preparer to use in preparing their tax returns for the calendar years 2002 through 2009.
These records omitted payments to Price or mischaracterized the payments to Price as
for legitimate purposes, such as "loans" or "reimbursement."
320. Fain did not issue any Forms W-2 or Forms 1099 for income paid to Price
byMMS.
321. Nealy did not issue Forms W-2 or Forms 1099 for income paid to Price,
except for a single false Form 1099 for the calendar year 2004 that underreported the
amount of money Nealy paid Price during that year.
322. Price filed false income tax returns with the Internal Revenue Service for
the calendar years 2002 through 2009 from which he omitted bribes and other taxable
income that he received during those calendar years.
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323. Price filed false Personal Financial Statements for the years 2002 through
2008 and 2010, signed under oath, in which he omitted the above-described sources of
income and ownership interests in certain parcels of real property.
Overt Acts in Furtherance of the Conspiracy
324. In furtherance of the conspiracy and to effect its objects and purposes, at
least one of the conspirators committed, and caused to be committed, one of the
following overt acts, among others, in the Dallas Division of the Northern District of
Texas, and elsewhere:
325. On July 5, 2002, Fain signed a document to give W.W. (an individual
known to the Grand Jury) the authority to sell her purported one-half interest in property
on Grady Niblo Road to Price. The property was one of three that Fain agreed to
purchase jointly with W.W. on Price's behalf as a straw purchaser in April1999 under
the business name of JWP (a business known to the Grand Jury). The other two
properties were located on Interstate 30 and Fairport Road (the specific locations of
which, and of the Grady Niblo property, are known to the Grand Jury).
326. On September 3, 2002, W.W. signed a warranty deed with a vendor's lien
transferring all of his rights in the Grady Niblo property to Price.
327. On September 3, 2002, Fain signed a quitclaim deed for the Grady Niblo
property relinquishing any interest she had in the property to Price.
Page 93 of 107
328. On or about December 26, 2002, Price obtained two cashier's checks made
payable to a title company in the total amount of$35,000 and gave them to Fain, who
used them as a down payment for a home loan that closed on or about January 4, 2003.
329. On or about April15, 2003, Price filed his 2002 Income Tax return
omitting bribes and other income, instead reporting a total income of$103,789 and
claiming a refund of $8,776 from his fraudulent and false return.
330. On or about Apri130, 2003, Price filed his state-law mandated 2002
Personal Financial Statement with the Dallas County Clerk, signed under oath and
omitting income sources and ownership interests in certain parcels of real property.
331. On or about August 15, 2003, Nealy endorsed a cashier's check made
payable to her for $2,000 from Business T. In the endorsement, Nealy wrote "pay to
order" of the nominee name for Price's account at City Bank. This endorsed cashier's
check was deposited into Price's nominee City Bank account ****6372 on or about
August 15, 2003.
332. On or about September 14,2003, Nealy paid Price $1,678 by check
number 4801 issued from Nealy's KLNA account ****1364 at Bank of America. Fain
deposited $1,000 from this check into Price's nominee City Bank account ****6372 on
or about September 15, 2003 and took $678 cash back from the deposit.
333. On or about February 11, 2004, Price filed his state-law mandated 2003
Page 94 of 107
334. On or about August 9, 2004, Price or Fain deposited into Price's nominee
account ****6372 at City Bank Nealy's KLNA check number 5167 in the amount of
$3,500, payable to Kathy L. Nealy and endorsed by Nealy. Fain signed for $3,000 cash
back from the proceeds.
335. On or about October 18, 2004, Price filed his 2003 Income Tax return
omitting bribes and other income, instead reporting a total income of $104,310 and
336. On or about January 31,2005, Fain opened MMS account ****0007 at
Lakeside National Bank, for which Price was the beneficiary and a convenience signer.
337. On or about February 22, 2005, Fain, as a straw owner for Price, sold her
interest in a parcel of real property on Fairport Road. Fain received $17,495.92 from the
real estate closing and immediately endorsed the check and gave it to Price. Price then
deposited the check into his Lakeside personal account ****2985.
338. On or about February 28, 2005, Business M paid Price $7,500 in proceeds
from the sale of African art.
339. On or about March 28, 2005, Price endorsed the back ofKLNA check
number 5497 issued from Nealy's KLNA account ****1364 at Bank of America in the
amount of$1,000, payable to Kathy L. Nealy with "salary" in the check's memo line, and
deposited it into his WFP nominee account ****6372 at City Bank.
Page 95 of 107
340. On or about May 2, 2005, Price filed his state-law mandated 2004 Personal
Financial Statement with the Dallas County Clerk, signed under oath and omitting
income sources and ownership interests in certain parcels of real property.
341. On or about August 16, 2005, Price filed his 2004 Income Tax return
342. On or about January 25, 2006, Price deposited a Business X check in the
amount of $57,031.51 made payable to MMS into MMS's Lakeside account number
****0007 and received $9,800 cash back.
343. On or about March 24, 2006, Price split-deposited a Business X check in
the amount of$23,128.24 made payable to MMS as follows: $14,128.34 into MMS's
Lakeside account number ****0007 and $3,000 into Price's personal Lakeside account
number ****1984. Price also received $6,000 in currency from the transaction.
344. On or about Aprill7, 2006, Business M paid Price $2,465.33 in proceeds
346. On or about June 30, 2006, Business Tpaid Price $1,200 by check number
2043.
Page 96 of 107
347. On or about September 27, 2006, Price deposited a Business X check in the
amount of $53,929.83 made payable to MMS into MMS's Lakeside account number
****0007 and received $9,500 cash back.
349. On or about December 6, 2006, Price and/or Fain split-deposited a
Business X check in the amount of $81,54 7.62 made payable to MMS as follows:
$21,547.62 into MMS's Lakeside account number ****0007 and $60,000 into Price's
personal Lakeside account number ****2985.
350. On or about March 13, 2007, Business M paid Price $4,551.07 in proceeds
351. On or about April30, 2007, Price filed his state-law mandated 2006
352. On or about May 14,2007, Nealy wrote and signed KLNA check number
6879, payable to MMS in the amount of $4,563.44, issued from Nealy's KLNA account
****1364 at Bank of America, with "Inv.# 2093" written in the check's memo line.
353. On or about May 18, 2007, Price deposited into his Lakeside National
Bank account ****1984, Nealy's KLNA check number 6879 in the amount of$4,563.44,
payable to MMS with "Inv.# 2093" written in the check's memo line.
Page 97 of 107
354. On or about July 2, 2007, Price split-deposited a Business X check in the
amount of $35,737.34 made payable to MMS and a second check in the amount of
$1,745.36 as follows: $3,482.70 into MMS's Lakeside account number ****0007 and
$25,000 into Price's personal Lakeside account number ****2985. Price also received
$9,000 in currency from the transaction.
356. On or about January 2, 2008, Price paid an individual associated with
Business M$2,320 out of his BOA Campaign account ****7956 for three pieces of
African Art. The next day, this same individual returned $2,185 to Price after deducting
a commission of $45 on each piece of Price's African Art that was "sold" to Price by
Business M the preceding day.
357. On or about January 12,2008, Price cashed Business Ts check number
2128 in the amount of $1,200 and received twelve $100 bills.
358. On or about February 27, 2008, Nealy wrote KLNA check number 131
payable to Dal Telco in the amount of$2,500, issued from Nealy's account ****2342 at
Morgan Stanley with "Repayment Loan" written in the check's memo line. Price
endorsed this check and cashed it on his Dallas Telco account ****1862, receiving 25
$100 bills.
Page 98 of 107
359. On or about June 26, 2008, Price filed his state-law mandated 2007
360. On or about August 1, 2008, Fain applied for an American Express
business account for MMS, with one of the credit cards issued in Price's name.
362. On or about April 30, 2009, Price filed his state-law mandated 2008
363. On or about May 1, 2009, Price endorsed the back ofKLNA check number
7858 issued on Nealy's KLNA account ****1364 at Bank of America, payable to Dallas
Telco in the amount of $3,000, and cashed it on his Dallas Telco account **** 1862. At
the same time, Price also cashed a $1 ,260 check from Business M representing the
proceeds of African art, and he received 42 $100 bills.
364. On or about July 21, 2009, Price cashed Business Ts check number 2345
in the amount of$1,200.
365. On or about August 5, 2009, Nealy wrote check number 1071 payable to
[K.M.], an individual associated with Business M The check was issued from Nealy's
Discover credit card account ****7391 in the amount of $750 and had "Artwork> Bal.
Page 99 of 107
due $750'"' written in the check's memo line. Price cashed this check on his Dallas
Telco account**** 1862.
claiming a refund of $15, 183 from his fraudulent and false return.
368. On or about January 26,2011, Price cashed Business Ts check number
2271 in the amount of $1,200 and received twelve $100 bills.
370. On or about June 27, 2011, Price maintained approximately $229,590 in a
safe at his residence.
371. The Grand Jury incorporates the following paragraphs of this indictment as
overt acts of this conspiracy: 33, 34, and 95.
All in violation of 18 U.S.C. 371.
Page 100 of 107

Counts Nine through Eleven

Subscribing to a False and Fraudulent U.S. Individual Income Tax Return
(Violation of26 U.S.C. 7206(1))
372. On or about the dates listed for each Count below, in the Dallas Division of
the Northern Distr.ict of Texas, defendant, John Wiley Price, a resident of Dallas, Texas,
did willfully make and subscribe a United States Individual Income Tax Return, Form
1040, which was verified by a written declaration that it was made under the penalties of
perjury and filed with the Internal Revenue Service, which said income tax return Price
did not believe to be true and correct as to every material matter in that Price falsely
reported his total income as the amounts in each of the calendar years set forth below,
when in truth and in fact, as he then well knew and believed, he had received additional
substantial income in each of the calendar years:
Falsely
Tax
Count Offense Date Reported Falsified Document
Year
Total Income
U.S. Individual Income
Nine 2007 October 14, 2008 $104,770
Tax Return, Form 1040

Ten 2008 October 15, 2009 $109,124
Eleven 2009 October 15, 2010 $109,758
Each in violation of26 U.S. C. 7206(1).
Page 101 of 107

Count Twelve
Attempt to Evade or Defeat Payment of Tax
(Violation of26 U.S.C. 7201)
373. On or about October 20,2003 and continuing through on or about June 27,
2011, in the Dallas Division of the Northern District of Texas, defendant, Kathy Louise
Nealy, a resident of Dallas, Texas, did willfully attempt to evade and defeat the payment
of a substantial tax due and owing by her to the United States of America for the calendar
tax years 2002 through 2009, in the total amount of approximately $626,363, by
affirmatively concealing and attempting to conceal from the Internal Revenue Service the
nature, extent, and location of her assets and income through a pattern of conduct
including, but not limited to:
a. conducting financial transactions at approximately ten different financial
institutions where she opened and used more than ten separate accounts;
b. avoiding depositing multiple checks payable to herself and her businesses,
KLNA and KNI, into her own accounts;
c. creating and maintaining inaccurate and/or imprecise business records,
accounting records, and bank records to obscure her sources and extent of income,
expenses, and debts;
d. encumbering and reducing her monthly net cash flow and assets by
amassing debts and other unnecessary financial obligations, which she chose to pay
instead of paying the Internal Revenue Service;
Page 102 of 107

e. divesting herself of assets and income through the acquisition of luxury
vehicles, an American Airlines Center suite, several parcels of real property, and other
lavish expenditures;
f. divesting herself of assets and income by paying hundreds of thousands of
dollars to Price in the form of direct and indirect payments, vehicle payments, and related
expenses in the bribery and mail fraud schemes alleged in Counts 1 through 7;
g. divesting herself of assets and income through charitable giving and
campaign contributions;
h. filing false or fraudulent returns in some years; and
1. signing a false and misleading real estate document in order to avoid
federal tax liens.
All in violation of26 U.S.C. 7201.
Page 103 of 107

Count Thirteen
False Statement
(Violation of 18 U.S.C. 1001)
374. On or about June 27, 2011, in the Dallas Division of the Northern District
of Texas, Defendant Dapheny Elaine Fain did knowingly and willfully make a
materially false, fictitious, and fraudulent statement and representation in a matter within
the jurisdiction of the Department of Justice- Federal Bureau of Investigation (FBI), a
department and agency of the United States, to wit, Fain made the following statements
to Special Agents of the FBI:
a. Price does not benefit from the business ofMMS.
b. Price has not transferred any of his money into an MMS account.
375. When Fain made these statements, Fain well knew that these statements
and representations were false, fictitious, and fraudulent.
All in violation of 18 U.S.C. 1001.
Page 104 of 107

Forfeiture Notice
(18 U.S.C. 981(a)(l)(C), 26 U.S.C. 853(p), and 28 U.S.C. 2461(c))
1. The allegations contained in the Introduction and Counts 1 through 7 of this
Indictment are hereby realleged and incorporated as if fully set forth herein for the
purpose of giving notice of forfeiture pursuant to Title 18, United States Code, Section
981(a)(l)(C) and Title 28, United States Code, Section 2461(c).
2. Upon conviction of an offense as set forth in Counts 1 through 7 of this
Indictment and pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title
28, United States Code, Section 2461(c), the defendants, John Wiley Price, Kathy
Louise Nealy, and Christian Lloyd Campbell shall forfeit to the United States of
America, any property, real or personal, which constitutes or is derived from proceeds
traceable to the offenses, including, but not limited to, a money judgment as a sum of
approximately $950,000 in United States currency, representing the total amount of
proceeds traceable to a violation of 18 U.S.C. 666, 1341, or a conspiracy to commit
any such offenses, for which the defendants are jointly and severally liable.
3. If any of the forfeitable property described in the above paragraphs, as a
result of any act or omission of a defendant, cannot be located upon the exercise of due
diligence; has been transferred or sold to, or deposited with, a third party; has been placed
beyond the jurisdiction of the court; has been substantially diminished in value; or has
been commingled with other property which cannot be divided without difficulty, the
United States of America shall be entitled to forfeiture of substitute property from that
Page 105 of 107

defendant 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), 26 U.S.C. 853(p), and 28 U.S.C.
2461(c).
Page 106 of 107

.
A TRUE BILL
SARAH R. SALDANA
UNITED STATES ATTO
Assistant Unite tates Attorney

State Bar No. 24038115
1100 Commerce St., Suite 300
Dallas, Texas 75242-1699
Telephone: 214.659.8600
Facsimile: 214.659.8805
walt.junker@usdoj .gov
KATHERINE MILLER
Assistant United States Attorney
State Bar No. 00789107
1100 Commerce St., Suite 300
Dallas, Texas 75242-1699
Telephone: 214.659.8600
Facsimile: 214.659.8805
katherine.miller@usdoj .gov
Page 107 of 107

.. .~
Case 3:14-cr-00293-M Document 1 Filed 07/23/14
. t
Page 108 of 109 PageID 108
--
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
U.S. DISTRICT COlOO'
NORTB:BllNDIST.RICT OP TBX'AS
THE UNITED STATES OF AMERIC FIT.,ED
v.
JOHN WILEY PRICE (0 1)

a.k.a John Wiley Price III
KATHY LOUISE NEALY (02)
DAPHENY ELAINE FAIN (03)
CHRISTIAN LLOYD CAMPBELL (04)
SEALED INDICTMENT
18 U.S.C. 371 (18 U.S.C. 666(a)(l)(B) and (a)(2))

Conspiracy to Commit Bribery Concerning a Local Government
Receiving Federal Benefits
18 U.S.C. 1341, 1346, and 2

Deprivation of Honest Services by Mail Fraud and Aiding and Abetting
26 u.s.c. 7206(1)
Subscribing to a False and Fraudulent U.S. Individual Income Tax Return
26 u.s.c. 7201
Attempt to Evade or Defeat Payment of Tax
18 u.s.c. 1001
False Statement
(13 COUNTS)
18 U.S.C. 98l(a)(l)(C), 26 U.S.C. 853(p), and 28 U.S.C. 2461(c)

Forfeiture Notice
A true bill rendered
;;~;:~;;---------------------------~--~~~-~-~----------i;;~;;;;;;;;c;~
.._.."""
Case 3:14-cr-00293-M Document 1 Filed 07/23/14
' .
Page 109 of 109 PageID 109
' .
~
.
Filed in open court this~ day of July, 2014.
Clerk
Warrants to be Issued
UNITED STATES 9-IS"FRK:T/MAGISTRATE JUDGE

No Criminal matter pending, paralled asset forfeiture case 3:12-CV-893-D pending for
Defendant's 1 & 3

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Case 3:14-cr-00293-M Document 1 Filed 07/23/14 Page 1 of 109 PageID 1

U.S. DISTRICT COURT

. - '- SEALED NIBmmRNFILEDOFtmrAS

(\V R\G\~ ~ IN TilE UNITED STATES DISTRICT ( OURT

UNITED STATES OF AMERICA

The Grand Jury Charges:

At all times material to this indictment:

1. Dallas County, Texas was a political subdivision of the State of Texas,

divided into four geographic precincts also known as "districts."

2. A five-member Commissioners Court was the primary governing body of

district, and a County Judge elected countywide.

3. The Commissioners Court presided over a variety of official matters,

involving grants, contracts, subsidies, loans, guarantees, insurance, or other forms of

budget of most departments, including those headed by other elected officials.

4. Defendant JOHN WILEY PRICE was an elected County Commissioner

shared information with and made recommendations to the Commissioners Court.

5. Each elected term, Price took an oath specific to County Commissioners

and Judges, in which he swore and affirmed:

and except such warrants as may issue to me as fees of office. So help me

duties of a County Commissioner, as well as to preserve, protect, and defend the

a person commits the offense of bribery if he intentionally and knowingly

(1) any benefit as consideration for the recipient's decision, optmon,

(3) any benefit as consideration for a violation of a duty imposed by law on

financial activity that included, among other things:

a. occupational income and rental income;

9. Similarly, Price was required to disclose all sources of income generated

outside of county employment pursuant to Dallas County Commissioners Court Order

2011-507 and Texas Local Government Code, Chapter 159.

also registered with the City of Dallas as a lobbyist.

11. Nealy advertised her services to include "political consulting" and

"access to contacts" necessary to "get the job done."

benefits from Nealy totaling approximately $950,000.

14. Defendant CHRISTIAN LLOYD CAMPBELL was a commissioned

Campbell Consulting Group (CCG). He and Nealy simultaneously contracted as

several occasions, Campbell successfully persuaded vendors to hire Nealy or to renew

her contracts for subsequent years.

15. Defendant DAPHENY ELAINE FAIN, a Dallas County employee,

C. DALLAS COUNTY CONTRACT BIDDING PROCESS

evaluation committee (also known as a selection committee) composed of county

vote on whether to accept or reject the committee's recommendations. Frequently, the

confidentiality of the proposals' contents, prevent disclosure to competing offerors, and

County. These included:

a. Texas Local Government Code, Section 262.0225, Additional Competitive

Procedures, which stated, in part:

b. Texas Local Government Code, Section 262.030, Alternative Proposal

If provided in the request for proposals, proposals shall be opened so as to

c. Chapters 74 and 86 of the Dallas County Code, which addressed

confidentiality and required that

all information protected by state statute concerning county business must

all information concerning county business must be held in strict

the selection process, except in county-sponsored inquiries, briefings, interviews, or

confidential, and to avoid improper or undue influence on the competitive bidding

19. Additionally, the RFPs and RFQs included conflict-of-interest provisions

or services," except on behalf of the County as an official or employee.

D. FOREIGN TRADE ZONE DESIGNATION PROCESS

20. In or about 2005, various property owners in Price's district became

interested in developing an area that would accommodate companies involved in

international trade through importing, re-exporting, and/or assembling foreign goods. A

inventory that was imported or that was to be exported.