THE GRAND JURY CHARGES:That on or about (date) in the ___________________ District of __________ defendant __________________________, being [an employer]* [an association of employers] [a person acting as a labor relations expert, advisor, and consultant to an employer] [a person acting in the interest of an employer] did unlawfully, willfully, and knowingly pay, lend, and deliver] and agree to pay, lend, and deliver a thing of value [and money in the approximate amount of $______] to (name of recipient) , an [officer/employee] of a labor organization, to wit:
(name of union) , [which represented/sought to represent/would have admitted to membership] the employees of (name of employer)] who were employed in an industry affecting commerce.*
All in violation of Title 29, United States Code,
Sections 186(a)(2) and (d)(2).**
* See 29 U.S.C. §§142 and 152.
** Participation in transaction occurring after October 12, 1984, and involving more than $1,000 of value is punishable as a felony; value of $1,000 or less is punishable as a misdemeanor.
[cited in JM 9-132.010]