Free Information - Felony - District Court of Delaware - Delaware

__ . Case 1 :07-cr—OOO32—JJF Document 2 H Filed O3/05/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
I n FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AIVIERICA, )
Plaintiff, )
v_ ) Criminal Action No. 07- gg; D;
JEFFERY C. VVILLIAMS, g .
Defendant. )
INFORNLATION
The United States Attorney for the District of Delaware charges thght; glam 5 Q
Count One !bi"E6¤lFifn—l I
2C€I°iE’£.EE€£ll§l;l.%tll£,..,.,,....._.-,
Introduction
1. At all times material to this Information, there existed a private management company
based in Wilmington, Delaware (the management company), that managed apartment complexes in
Delaware and received in excess of $10,000 in grants, contracts, subsidies, loans, guarantees,
insurance and other forms of federal assistance from the United States Department of Housingaand
Urban Development (HUD) during the calendar year 2005 , and therefore was an organization within
the meaning of Title 18, United States Code, Section 666(a) and (b).
2. At all times material to this Information, the defendant, Jeffrey C. Williams, was an agent l
of the management company, in that the defendant was the property manager of its apartment
complexes in New Castle County, Delaware — specifically, the Kimberton Apartments, the
Stoneybrook Apartments, and the Carleton Court Apartments.
3. From on or about August 11, 2005, through on or about October 6, 2005, in the District
of Delaware, the defendant, Jeffrey C. Williams, fraudulently caused the management company to

_ , Case 1 :07-cr—OOO32—JJF Document 2 Filed O3/05/2007 Page 2 of 2
issue checks payable to third-party service providers based on false invoices that he created and
issued to the management company. The defendant then deposited those checks into his bank
account and converted the ftmds to his own use. During the time period specified herein, the amount
of these checks issued by the management company exceeded the stun of $5,000, specifically $9,439,
as follows:
Date of Check Check Number Amount of Check
9/08/05 11456 $3,340
9/01/05 10438 $2,195
10/06/05 10538 $3,720
8/1 1/05 10406 $184 1
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Charging Paragraph
4. From on or about August ll, 2005, through on or about October 6, 2005, in the District i
of Delaware, the defendant, Jeffrey C. Williams, being an employee ofthe management company
which received in excess 0f$10,000 federal assistance during the calendar year 2005, intentionally
did steal property valued at $5,000 or more and owned by and under the care, custody, and control
of the management company, in violation of Title 18, United States Code, Section 666(a)(l)(A)(i)
and (ii).
COLM F. CONNOLLY
United States Att } t
A 4! ( 4
A / Edmond r inf
Assistant Unite tates Attorney
Dated: g -;/07
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