This document is available in two formats: this web page (for browsing content) and PDF (comparable to original document formatting). To view the PDF you will need Acrobat Reader, which may be downloaded from the Adobe site. For an official signed copy, please contact the Antitrust Documents Group.

    
IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

FILED


2009 AUG 31 P 4:41

CLERK US DISTRICT COURT
ALEXANDRIA, VIRGINIA


UNITED STATES OF AMERICA,    

                  v.

BRYAN LEE BURROWS,

                  Defendant.

)
)
)
)
)
)
)
)
)         
Case No.: 1:09-CR-392

Count 1: 18 U.S.C. § 371
(Conspiracy to Solicit Kickbacks)

Filed: August 31, 2009



CRIMINAL INFORMATION

THE UNITED STATES ATTORNEY CHARGES THAT:

COUNT 1
(Conspiracy to Solicit Kickbacks)

From in or about February 2009 to in or about May 2009, in the Eastern District of Virginia and elsewhere, BRYAN LEE BURROWS and others known and unknown to the United States Attorney unlawfully, willfully, and knowingly combined, conspired, confederated, and agreed together and with each other to commit offenses against the United States of America, to wit, to violate Title 41, United States Code, Section 53, by knowingly and willfully soliciting one or more kickbacks, specifically, money, payments, and commissions, in connection with the award of a private security services subcontract relating to a prime contract entered into by the United States, known as the Afghanistan Infrastructure Rehabilitation Project ("AIRP") in violation of Title 18, United States Code, Section 371. In furtherance of the conspiracy and to effect the objects and purposes thereof, BURROWS and co-conspirators performed overt acts, including, but not limited to, soliciting kickbacks from vendors located in the Eastern District of Virginia and elsewhere to be paid, in part, to a prime contractor agent in exchange for favorable treatment in connection with the award of a private security services subcontract to protect U.S. government personnel and contractors operating under the AIRP.

(In violation of Title 18, Unites States Code, Section 371)

Respectfully submitted,  


  Dana J. Boente
United States Attorney
  Robert E. Connolly
Chief, Philadelphia Office
Antitrust Division
U.S. Department of Justice
By:    _______________/s/________________
Kimberly A. Justice
Special Assistant United States
Attorney
United States Attorney's Office
2100 Jamieson Avenue
Alexandria, VA 22314
703-299-3819
Fax: 703-299-3981
kimberly.justice@usdoj.gov


_______________/s/________________
Timothy D. Belevetz
Assistant United States Attorney
2100 Jamieson Avenue
Alexandria, VA 22314
703-299-3819
Fax: 703-299-3981
timothy.d.belevetz@usdoj.gov


By:   


______________/s/________________
Joseph Muoio
Kimberly A. Justice
Attorneys, Antitrust Division
U.S. Department of Justice
Philadelphia Office
The Curtis Center, Suite 650 West
170 S. Independence Mall West
Philadelphia, PA 19106
215-597-7401
Fax: 215-597-8838
joseph.muoio@usdoj.gov


Steven A. Tyrrell
Chief, Fraud Section
Criminal Division
U.S. Department of Justice

    By:    _______________/s/________________
Bradford L. Geyer
Trial Attorney
Fraud Section, Criminal Division
U.S. Department of Justice
1400 New York Avenue, NW
Washington, DC 20005
215-939-5890
Fax: 215-597-8838
bradford.geyer@usdoj.gov