`
`LED
`IN THE UNITED STATES DISTRICT COURT F “
`FOR THE WESTERN DISTRICT OF TEX4gj 3) -8 P 3 58
`SAN ANTONIO DIVISION
`
`“24, US DISTRICT COUR
`(cau
`OISTRICTOF TEP
`
`S AO9 |
`
`»
`
`Violation: 18 U.S.C. § 371
`(Conspiracy)
`
`UNITED STATES OFAMERICA
`
`v.
`
`)
`)
`)
`
`) )
`
`)
`
`NYREE PETTAWAY,
`
`Defendant.
`
`The United States, by and through its attorneys, charges:
`
`INFORMATION
`
`Case 5:09-cr-00549-XR Document 1 Filed 07/08/09 Page 1 of 5
`
`
`
`1.
`
`For purposesofthis Information, the relevant period is that period from in or
`
`about December 2006 until in or about November 2007. From on or about June 30, 2004 until in
`
`or about December 2005, defendant’s uncle, John Cockerham, a Major in the U.S. Army, was
`
`deployed to Camp Arifjan, Kuwait, as.a Contracting Officer. In or about November 2005,
`
`defendant relocated to Kuwait to accept employment with a contractor working at Camp Arifjan.
`
`2.
`
`In or about 2005, John Cockerham demanded, sought, received, accepted, and
`
`agreed to receive and accept at least $9.6 million in bribes from contractors in return for
`
`awarding contracts and performing contracting actions on behalf ofthose contractors.
`
`3.
`
`In or about 2005, John Cockerham’s family and associates, including, among
`
`others, his sister, Carolyn Blake, and his wife, Melissa Cockerham,received these bribe
`
`payments from contractors on John Cockerham’s behalf. In or about 2005, Blake received
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`approximately $3.1 million and Melissa Cockerham received approximately $1.9 million,all
`
`paid in cash in United States, Kuwaiti, and Emirati currency.
`
`4.
`
`In or about 2005, Blake, Melissa Cockerham, and others placed at least
`
`
`
`Case 5:09-cr-00549-XR Document1 Filed 07/08/09 Page 2 of 5
`Case 5:09-cr-00549-XR Document 1 Filed 07/08/09 Page 2 of 5
`
`$3.6 million in United States and Kuwaiti currency, received as bribe payments from contractors
`
`on John Cockerham’s behalf, in safe deposit boxes in Kuwait.
`
`5.
`
`On or about December 20, 2006, criminalinvestigators searched John
`
`Cockerham’s and Melissa Cockerham’s house, and uncovered evidence that moneypaid as
`
`bribes to John Cockerham was received by Blake, Melissa Cockerham,and others, and was kept
`
`in safe deposit boxes in Kuwait and elsewhere.
`
`COUNT ONE
`18 U.S.C. § 371
`(Conspiracy To Obstruct Justice)
`
`
`
`Paragraphs1 through 5 ofthis Information are incorporated by referenceas if fully stated
`
`herein, and the followingis further alleged:
`
`6.
`
`From in or about January 2007 until at least in or about November 2007, the exact
`
`dates being unknown,in the Western District of Texas, Kuwait, and elsewhere, defendant
`
`NYREE PETTAWAY
`
`and others known and unknown did knowingly and unlawfully combine, conspire, confederate,
`
`and agree to commit an offense against the United States,thatis:
`
`(a)
`
`to corruptly alter, destroy, mutilate, and conceal records, documents, and
`
`other objects, and attempt to do so, with the intent to impair the object’s integrity and
`
`availability for use in an official proceeding, and otherwise obstruct, influence, and
`
`impede an official proceeding, and attempt to do so, in violation of Title 18, United States
`
`Code, Section 1512(c)(1), (2); and
`
`(b)—tocorruptly persuade another person, and attempt to do so, and engage in
`
`misleading conduct toward another person, with intent to influence, delay, and prevent
`
`
`
`Case 5:09-cr-00549-XR Document1 Filed 07/08/09 Page 3of5
`Case 5:09-cr-00549-XR Document 1 Filed 07/08/09 Page 3 of 5
`
`the testimony of a person in an official proceeding, and cause and induceapersontoalter,
`destroy, mutilate, and conceal objects with intent to impair the object’s integrity and
`availability for use in an official proceeding,in violation ofTitle 18, United States Code,
`
`
`
`Section 1512(b)(1), (2)(B).
`
`OBJECT OF THE CONSPIRACY
`
`7.
`It was an object of the conspiracy for defendant and others to misrepresentthe
`source offunds, to create fraudulent and misleading agreements and other documentsin an effort
`
`to make the source ofpayments madeby contractors to John Cockerham andhis assignees appear
`
`legitimate, to conceal cash andgive cash to others for safekeeping in an effort to preventits
`
`availability for use in official proceedings, and otherwise to obstruct, influence, and impede the
`
`investigation.
`|
`
`MANNERAND MEANSOF THE CONSPIRACY
`
`It was a part ofthe conspiracy that defendant and others would, amongotherthings, do
`
`the following:
`
`8.
`
`communication among co-conspirators.
`
`Create an email address under an assumed nametofacilitate undetected
`
`9.
`
`Create fraudulent and misleading agreements and other documents to make the
`
`source ofpayments made by contractors to John Cockerham andhis assignees appear legitimate.
`.
`10.
`Deliver the fraudulent and misleading agreements and other documents to co-
`
`conspirators for their signature andratification.
`
`11.
`
`Direct co-conspirators to destroy evidence and makefalse statements and
`
`representations if questioned by investigators.
`
`
`
`Case 5:09-cr-00549-XR Document1 Filed 07/08/09 Page 4of5
`Case 5:09-cr-00549-XR Document 1 Filed 07/08/09 Page 4 of 5
`
`12.
`
`Give money to co-conspirators for safekeeping to impair the money’s availability
`
`for use in an official proceeding.
`
`13.
`
`Makefalse statements and representations when questioned byinvestigators.
`
`
`
`OVERT ACTS
`
`In furtherance of the conspiracy and in order to accomplishits objects, the following
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`overt acts, among others, were committed by defendantand others in the Western District of
`
`Texas, Kuwait, and elsewhere:
`
`14.
`
`In or about December 2006, in Texas, John Cockerham approached defendant for
`
`help relaying messages, passing documents, and delivering money to co-conspirators in Kuwait.
`
`Defendantagreed to do so upon her return to Kuwaitlater that month.
`15.
`Inorabout January 2007, defendant created the email account
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`praystandbestill@yahoo.com under the assumed name Jane Johnson,in order to facilitate
`
`undetected communication among co-conspirators.
`
`16.
`
`In or about January 2007, defendant delivered fraudulent and misleading
`
`agreements and other documents to the contractors and requested their signatures on these
`
`documents.
`
`17.
`
`In or about January 2007, defendant returned one ofthese fraudulent agreements
`
`to John Cockerham in San Antonio,after obtaining the contractor’s signature and corporate
`
`stamp on the document which the contractor back-dated to August 16, 2006.
`
`18.
`
`In or about January 2007, Blake retrieved approximately $3 million cash from
`
`safe deposit boxes in Kuwait and gave the money to defendant.
`
`19.
`
`In or about January 2007, defendantdelivered cash to co-conspirators for
`
`
`
`
`
`ormenmmomrrmnw =aSe B:09-cr-00549-XR Document1 Filed 07/08/09 Page5of5
`Case 5:09-cr-00549-XR Document 1 Filed 07/08/09 Page 5 of 5
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`safekeeping, out of reach of criminal investigators.
`
`20.
`
` Onor about November 17, 2007, defendant made false statements and
`
`representationsto investigators when questioned.
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`(All in violation of Title 18, United States Code, Section 371)
`
`DATED: iy , 2004
`
`,atWashington,D.C.
`
`Forthe United States
`
`LISA M. PHELAN,Chief
`National Criminal Enforcement Section
`Antitrust Division
`
` By:
`
`Emily W, Allen, Trial Attorney
`Mark W.Pletcher, Trial Attorney
`National Criminal Enforcement Section
`United States Department of Justice
`Antitrust Division
`450 Fifth Street, NW; Suite 11300
`Washington, DC 20005
`
`By:
`
`WILLIAM M. WELCHII, Chief
`Public Integrity Section
`Criminal Division
`
`
`ard B. Evans,
`
` Trial Attofyney P
`
`Public Integrity Section
`artment of Justice
`United States Dep.
`Criminal Division
`1400 New York Ave., NW
`
`Washington, DC 20005
`
`
`
`
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