THE GRAND JURY CHARGES:That on or about (date) in the ____________ District of __________ the defendant __________________________, [a]n [employer] * [association of employers] [person acting as a labor relations expert, advisor, and consultant to an employer] [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
(name of union) , a labor organization engaged in an industry affecting commerce,* with intent to influence him/her in respect to his/her actions, decisions, and duties as [a representative of employees] [such officer/employee of (name of union) ].
All in violation of Title 29, United States Code, Sections 186(a)(4) 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]