Case 3:14-cr-00388-MMA Document 336 Filed 07/08/16 PageID.

2341 Page 1 of 23

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_DENITY

5 UNITED STATES DISTRICT COURT

6 SOUTHERN DISTRICT OF CALIFORNIA

7 March 2015 Grand Jury

8 UNITED STATES OF AMERICA, Case No. 14CR0388-MMA

9 Plaintiff, I N D I C T MEN T
-(3rd supersedIng)-
10 v.
Title 18, U.S.C., Sec. 371 -
11 JOSE SUSUMO AZANO MATSURA (1), Conspiracy to Commit Offenses
aka Mr. A., Against the United States;
12 aka Mr. Lambo, Title 2, U.S.C.,
RAVNEET SINGH (2), Secs. 437g(d) (1) (A) and
13 aka Ravi Singh, 441e(a) (1) (A) - Campaign Donation
ELECTIONMALL, INC. (3), or Contributi'on by a Foreign
14 MARCO POLO CORTES (4), National Aggregating At Least
EDWARD SUSUMO AZANO HESTER (5), $25,000; Title 2, U.S.C.,'
15 Secs. 437g (d) (1) (A) and 441f -
aka Susu,
aka Junior, Contribution in the Name of
16 Another Aggregating At Least
$25,000; Title 18, U.S.C., Sec.
17 1519 - Falsification of Records;
Defendants. Title 18, U.S.C., Sec. 201(b) -
18 Bribery; Title 18, U.S.C., Sec. 2-
Aiding and Abetting; Title 18,
19 U.S.C., Sec. 922 (g) (5) (B) - Alien
in Possession of a Firearm;
20 Title 18, U.S.C., Secs. 924(g) and
981(a) (1) (C) and Title 28, U.S.C.,
21 Sec. 2461(c) - Criminal
Forfeiture '
~--------------------------------~
22

23 The grand jury charges:

24 The Integrity of the Electoral Process

25 1. United States citizens have a right to choose their

26 political representatives through free and fair elections. To promote

27
As of September 1, 2014, the relevant Federal Election Campaign
1
28
statutes were reclassified at Title 52, United States Code,
Sections 30109, 30121, and 30122.
AGS:nlv(2) :San Diego: 7/8/16
 , Case 3:14-cr-00388-MMA Document 336 Filed 07/08/16 PageID.2342 Page 2 of 23

1 the integrity of these elections, Congress enacted a series of rules

2 that govern campaign fundraising.

3 2. These campaign finance rules are integral to democracy and

4 in ensuring accountability and transparency in elections.

5 3. Congress promotes transparency in elections by prohibiting

6 the use of "conduit contributions" made by "straw" donors, as well as

7 other methods designed to conceal the source of campaign financing. A

8 conduit contribution is one that is made by a person (referred to as

9 the straw donor) on behalf of another person who reimburses the straw

10 donor for the money given to the candidate.

11 4. In addition to prohibiting conduit contributions, Congress

12 attempted to curtail foreign influence in elections by prohibiting any

13 "foreign national" from making donations, contributions, or

14 expenditures in support of any candidate at the federal, state, or

15 local level. A "foreign national" is an individual who is not a

16 United States citizen or national, and who is not a lawful permanent

17 resident of the United States.

18 Campaigns for Elective Office in San Diego

19 5. In 2012 and 2013, a series of elections took place within

20 the Southern District of California. During the 2012 primary election

21 cycle, a person hereinafter referred to as "Candidate 1" ran for the

22 office of Mayor of San Diego.

23 6. During the 2012 primary and general election cycles, a

24 person hereinafter referred to as "Candidate 2" ran for the office of

25 United States Representative for the 51st Congressional District of

26 California.

27

28

2
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1 7. Also during the 2012 primary and general election cycles, a

2 person hereinafter referred to as "Candidate 3" ran for the office of

3 Mayor of San Diego.

4 8. During a 2013 special election cycle, a person hereinafter

5 referred to as "Candidate 4" ran for the office of Mayor of San Diego.

6 Campaign Finance Methods and Public Records

7 9. During the above elections, there were various ways to

8 legally provide financial assistance to a candidate's campaign for

9 office.

10 10. For example, a United States citizen could make a

11 contribution or donation directly to a candidate. Contributions and

12 donations could be made in the form of money, or in the form of some

13 other thing of value, such as goods or services. When a person made a

14 donation in the form of goods or services, it would generally be

15 referred to as an "in-kind" contribution or donation.

16 11. Also for example, a U.S. citizen could make a contribution

17 or donation to an independent expenditure committee, also referred to

18 as an "IE," "PAC," or "SuperPAC." Similarly, a citizen could make a

19 contribution or donation to a committee of a political party. These

20 independent expenditure committees and political party committees, in

21 turn, could spend the money to support a particular candidate.

22 12. These various types of financial support and in-kind

23 spending had to be reported to government agencies, which maintained

24 records that the public and law enforcement agencies could access.

25 13. For instance, the Federal Election Commission maintained a

26 record of contributions made in connection with federal elections.

27 The State of California maintained a record of donations to political

28 committees organized at the county level. The City of San Diego

3
 • Case 3:14-cr-00388-MMA Document 336 Filed 07/08/16 PageID.2344 Page 4 of 23
I ' ,r

1 maintained a record of donations to campaigns and independent

2 expenditure committees, as well as a record of expenditures made by
3 independent expenditure committees.
4 Individuals Involved

5 14. JOSE SUSUMO AZANO MATSURA, aka Mr. A., aka Mr. Lambo
6 ("AZANO"), was a businessman who maintained residences around the
I
7 country, including two houses in Coronado, California. Among other
8 things, AZANO provided eavesdropping software and other technology to
9 foreign governments.

10 15. Although maintaining residences in Coronado, AZANO was a

11 Mexican citizen, and had never applied for, nor obtained,
\

12 United States citizenship or lawful permanent resident status in the

13 United States. As a result, AZANO was a "foreign national" and thus
14 prohibited from making donations and contributions directly or
15 indirectly in support of any candidate for elective office in the
16 United States at the federal, state, or local level.

17 16. In or about 2011, AZANO began to insert himself in San Diego

18 politics. As part of his involvement, AZANO attempted to ingratiate

19 himself with San Diego politicians and made large donations in support
20 of candidates for elective office in San Diego.

21 17. RAVNEET SINGH, aka Ravi Singh ("SINGH") , was the President
22 of ELECTIONMALL, INC. ("ELECTIONMALL") and at all times worked on its

23 behalf and for its benefit. According to its website, ELECTIONMALL

24 specialized in providing social media services to political campaigns
25 throughout the world. SINGH, who styled himself as a "campaign guru,"
26 worked principally out of offices in Washington, D.C.

27 18. Marc Alan Chase ("Chase" ) (charged elsewhere), was a

28 United States citizen and the managing member of South Beach

4
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.'

1 Acquisitions, Inc. (charged elsewhere) and West Coast Acquisitions,

2 LLC (charged elsewhere). On behalf of and at the direction of AZANO,
3 Chase: (i) recruited straw donors to make indirect donations on
4 AZANO's behalf to Candidate 1 and paid them back with AZANO's funds;
5 and (ii) agreed to make indirect contributions and donations on
6 AZANO's behalf to independent expenditure committees and political
7 party committees for Candidates 2 and 3 through his company's checking
8 accounts, knowing that he would be reimbursed by AZANO for those
9 checks.

10 19. EDWARD SUSUMO AZANO HESTER, aka Susu, aka Junior

11 ("E.S. AZANO"), was a United States citizen and AZANO's son. On behalf
12 of and at the direction of AZANO, E.S. AZANO recruited straw donors to
13 make indirect donations on AZANO's behalf to Candidate 1.
14 20. "J.W." was a United States citizen who worked for AZANO. On
15 behalf of AZANO and at the direction of E.S. AZANO, J.W. recruited
16 straw donors to make indirect donations on AZANO's behalf to
17 Candidate 1.

18 21. "D.D." was a United States citizen and E.S. AZANO's business

19 associate and friend. On behalf of AZANO and at the direction of

20 E.S. AZANO, D.D. recruited straw donors to make indirect donations on
21 AZANO's behalf to Candidate 1.
22 22. "E.L." was a United States citizen and AZANO's personal
23 secretary. On behalf of and at the direction of AZANO, E.L. recruited
24 straw donors to give indirect donations on AZANO's behalf to

25 Candidate 1.

26 23. Ernesto Encinas ("Encincas") (charged elsewhere), was a

27 retired San Diego Police Department ("SDPD" ) detective and the owner

28
5
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1 of a private security and consulting business. Among other jobs,

2 Encinas oversaw AZANO's protection detail.

3 24. MARCO POLO CORTES ("CORTES") was a San Diego-based lobbyist.

4 According to public filings, CORTES lobbied SDPD officials, city

5 councilmembers, members of council staff, and mayoral staff on a

6 variety of political issues.

7 FBI's Jurisdiction

8 25. The Federal Bureau of Investigation ("FBI") was a

9 United States executive branch agency. Among other things, the FBI

10 was responsible for investigating the potential influence of foreign

11 money in American elections, including the donations, contributions,

12 and expenditures of foreign nationals. The FBI was further

13 responsible for investigating illegal campaign contributions and

14 expenditures of all types, as well as the bribery and attempted

15 bribery of public officials.

16 Count 1: Conspiracy

17 (18 USC § 371)

18 26. Paragraphs 1 through 25 of this Indictment are realleged and

19 incorporated by reference.

20 27. Beginning on a date unknown and continuing up through

21 September 2013, within the Southern District of California and

22 elsewhere, defendants JOSE SUSUMO AZANO MAT SURA , aka Mr. A., aka

23 Mr. Lambo, RAVNEET SINGH, aka Ravi Singh, ELECTIONMALL, INC., MARCO

24 POLO CORTES, and EDWARD SUSUMO AZANO HESTER, aka Susu, aka Junior,

25 knowingly conspired together and with Ernesto Encinas (charged

26 elsewhere), Marc Alan Chase (charged elsewhere), and others to commit

27 offenses against the United States, to wit:

28

6
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1 a. Campaign Donations and Contributions by a Foreign

2 National Aggregating At Least $25,000 in a Calendar

3 Year, in violation of Title 2, United States Code,

4 Sections 437g (d) (1) (A) and 441e (a) (1) (A) (recodified at

5 Title 52, United States Code, Sections 30109 (d) (1) (A)

6 and 30121(a) (1) (A)); and

7 b. Falsification of Records, in violation of Title 18,

8 United States Code, Section 1519.

9 Manner and Means of the Conspiracy

10 28. In furtherance of this conspiracy, and to effect its

11 objects, defendants JOSE SUSUMO AZANO MATSURA, aka Mr. A., aka
12 Mr. Lambo, RAVNEET SINGH, aka Ravi Singh, ELECTIONMALL, INC., MARCO
13 POLO CORTES, EDWARD SUSUMO AZANO HESTER, aka Susu, aka Junior, and

14 other conspirators used the following manner and means, among others:

15 a. AZANO and others surveyed candidates for various

16 elective offices in San Diego to determine which ones

17 they should support.

18 b. AZANO sought private meetings with candidates.

19 c. Encinas and CORTES acted as intermediaries for AZANO,

20 communicating with campaign staff and other

21 stakeholders about how AZANO might be able to lend

22 financial support.

23 d. Once AZANO decided to support a candidate, he and his

24 co-conspirators designed secret, illicit methods of

25 contributing to the candidate's campaign, knowing that

26 AZANO could not finance the campaigns directly because

27 of campaign contribution/donation limits and his status

28 as a foreign national.
7
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1 e. On some occasions, AZANO used individuals as conduits,

2 or "straw donors," to facilitate his campaign

3 donations. These straw donors would be provided with

4 money up front, or reimbursed later, for any donations

5 they made on his behalf.

6 f. On yet other occasions, AZANO recruited a family member

7 to locate other potential "straw donors," who were

8 willing to funnel AZANO's money to candidates.

9 g. On one occasion, AZANO recruited Chase to act as a

10 conduit to illegally funnel large amounts of cash. At

11 AZANO's direction, Chase wrote checks to political

12 parties and independent expenditure committees that

13 would support AZANO's chosen candidates. AZANO also

14 used companies and an independent expenditure committee

15 of his own creation to direct money to the candidates

16 he supported.

17 h. As AZANO used increasingly secret ways of influencing

18 political campaigns, he and SINGH arranged unreported

19 in-kind contributions to various candidates. In

20 particular, using his company, ELECTIONMALL, SINGH

21 provided social media services to candidates that AZANO

22 supported.

23 i. AZANO funded ELECTIONMALL' s services, using a Mexico-

24 based company to transmit payment to ELECTIONMALL's

25 bank account, and never provided any invoice or other

26 bill of costs to the campaigns themselves.

27 j . Ultimately, AZANO,. SINGH, CORTES, and others ensured

28 that AZANO's name did not appear on public filings in

8
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1 connection with the illegal contributions and donations

2 because they knew AZANO was not allowed to finance
3 campaigns directly as a foreign national, and they knew
4 it was illegal to evade campaign contribution and
5 donation limits in the manner AZANO was doing.
6 Overt Acts
7 29. In furtherance of the conspiracy and to effect its objects,
8 the following overt acts, among others, were committed within the
9 Southern District of California and elsewhere:
10 Early Financial Support of Candidate 1

11 a. In late December 2011, AZANO instructed E.S. AZANO to

12 recruit friends and associates to act as straw donors

13 to make indirect donations on AZANO's behalf to

14 Candidate 1.

15 b. In late December 2011, E.S. AZANO delivered thousands

16 of dollars in cash, as well as preprinted envelopes, to

17 straw donors whom he had recruited for AZANO. In late

18 December 2011, AZANO instructed E.L. to recruit one of

19 his employees, "A. G. ," to act as straw donor (along

20 with A.G.'s wife) to make indirect donations on AZANO's

21 behalf.

22 c. On December 21, 2011, J.W. (a straw donor recruited by

23 E.S. AZANO) sent an email to six of his friends,

24 stating in part: "I need to get a $500 check from you

25 to help Susu and His Father support the soon to be

26 Mayor Bonnie Dumanis. We will give you the cash right

27 away so you won't lose any money but your support is

28 appreciated and very much needed."

9
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1 d. On December 23, 2011, E.L. deposited $1,000 in A.G.' s

2 bank account to reimburse A.G. for the check he and his

3 wife submitted to Candidate 1 on behalf of AZANO.

4 e. In late December 2011, AZANO instructed Chase to

5 recruit employees and friends to act as straw donors to

6 make indirect donations to Candidate 1 on AZANO's

7 behalf .

8 f. In late December 2011, AZANO caused approximately

9 $10,000 in cash, as well as preprinted envelopes, to be

10 delivered to Chase.

11 g. Between December 2011 and January 2012, as instructed,

12 Chase recruited employees and friends to donate to

13 Candidate 1, giving them each between $500 and $1,000

14 of the money AZANO had provided, and advising many that

15 the cash had come from AZANO.

16 h. In late 2011 or early 2012, AZANO met Candidate 1 at

17 AZANO's Coronado house.

18 i. In about May 2012, AZANO agreed to create, and did help

19 create, an independent expenditure committee supporting

20 Candidate 1.

21 j . On or about May 2, 2012, AZANO contributed $100,000 to

22 the independent expenditure committee.

23 AZANO's In-Kind Donations to Candidate 1

24 k. On or about February 26,2012, ELECTIONMALL sent an

25 email, copying SINGH and AZANO, and attaching an

26 invoice that reflected $75,000 for "promot[ing]" online

27 outreach in support of Candidate 1.

28
10
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1 1. On or about March 13, 2012, ELECTIONMALL sent another

2 email, again copying SINGH and AZANO, stating:

3 "Enclosed is the invoice for the betty boo proj ect for

4 lOOk it was originally 75 but Mr Singh explained the

5 need for the additional 25 during his last visit to

6 San Diego and Mr A verbally agreed [sic]."

7 m. On or about June 13, 2012, SINGH sent an email to

8 Encinas telling him not to discuss their illegal

9 campaign financing in writing, only in person.

10 Specifically, in response to an Encinas email

11 concerning SINGH's unreported services for Candidate 1,

12 SINGH wrote, in part, "I am not responding to this

13 email. Because of the legal ramifications. Please

14 talk to me . . . in person."

15 AZANO's Straw Donations to Candidates 2 and 3

16 n. On or about August 17, 2012, AZANO, CORTES, Encinas,

17 and Candidate 3 met at AZANO's house in Coronado,

18 California.

19 o. On or about August 21, 2012, CORTES received, and

20 forwarded to Encinas, an email from a representative of

21 Candidate 2 that included a link to the Federal

22 Election Commission's rules governing the prohibition

23 against contributions by foreign nationals.

24 p. On or about September 17, 2012, AZANO met Candidate 2

25 for dinner in downtown San Diego.

26 q. In about August and September, 2012, AZANO, CORTES, and

27 Encinas discussed how best to support Candidate 2's and

28 Candidate 3's campaigns.

11
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1 r. In or about September 2012, AZANO instructed Chase to

2 make certain large contributions and donations in

3 support of Candidates 2 and 3.

4 s. On or about September 24, 20l2, at AZANO's direction,

5 Chase wrote a $30,000 check to a political party

6 committee associated with Candidate 2' s campaign for

7 federal office.

8 t. On or about September 27, 2012, at AZANO's direction,

9 Chase wrote a $120,000 check to an independent

10 expenditure committee supporting Candidate 3's campaign

II for mayor.

12 u. On or about September 27, 20l2, at AZANO's direction,

13 Chase wrote a $30,000 check to a political party

14 commi ttee associated with Candidate 3' s campaign for

l5 mayor.

16 v. In September or October 20l2, CORTES personally

17 delivered the $l20,000 check to a representative of the

18 independent expenditure committee.

19 w. On or about October 2, 20l2, AZANO caused a $380,000

20 check to be given to Chase to cover the purchase of

21 $200,000 worth of artwork and $l80,000 as

22 reimbursements for the campaign contributions he had

23 written on or about September 24 and 27, 20l2.

24 AZANO's In-Kind Donations to Candidate 3

25 x. In or about October 20l2, SINGH, Encinas, and CORTES

26 visi ted Candidate 3' s campaign offices and told staff

27 that they were authorized to handle Candidate 3's

28 social media efforts.

l2
, .'
Case 3:14-cr-00388-MMA Document 336 Filed 07/08/16 PageID.2353 Page 13 of 23

1 y. In or about October 2012, when asked to provide a quote

2 for their services, SINGH represented that the expenses

3 would be "taken care of."

4 z. In or about October 2012, SINGH and CORTES created a

5 "war room" within the campaign offices of Candidate 3.

6 aa. On or about October 15, 2012, AZANO caused a Mexico-

7 based company to transmit $96,980 to ELECTIONMALL (via

8 a bank account for eSolutions R&D Lab, LLC) for the

9 purpose of funding social media services supporting

10 Candidate 3.

11 bb. On or about October 29, 2012, AZANO caused the same

12 Mexico'-based company to transmit $94,975 to

13 ELECTIONMALL (via a bank account for eSolutions R&D

14 Lab, LLC) for the purpose of funding social media

15 services supporting Candidate 3.

16 cc. In or about December 2012, AZANO invited Candidate 3 to

17 his home in Coronado Cays.

18 The Special Mayoral Election

19 dd. On or about August 1, 2013, 'acting as AZANO's agent,

20 Encinas spoke with a personal friend of Candidate 4

21 (who did not know about the meeting) and asked whether

22 Candidate 4 would be interested in "foreign

23 investment."

24 ee. On or about August 28, 2013, Encinas and CORTES met

25 with the friend of Candidate 4 (who did not know about

26 the meeting) to discuss how AZANO might be able to

27 support his candidacy.
28 All in violation of Title 18, United States Code, Section 371.
13
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1 Count 2: Conspiracy

2 (18 USC § 371)

3 30. Paragraphs 1 through 25 of this Indictment are realleged and
4 incorporated by reference.
5 31. Beginning on a date unknown and continuing through September
6 2013, within the Southern District of California and elsewhere,
7 defendants JOSE SUSUMO AZANO MATSURA, aka Mr. A., aka Mr. Lambo, and
8 MARCO POLO CORTES knowingly conspired together and with Ernesto
9 Encinas (charged elsewhere), Marc Alan Chase (charged elsewhere), and
10 others to commit an offense against the United States to wit,
11 Contribution in the Name of Another Aggregating At Least $25,000 in a
12 Calendar Year, in violation of Title 2, United States Code,
13 Sections 437g(d) (1) (A) and 441f (recodified at Title 52, United States
14 Code, Sections 30109 (d) (1) (A) and 30122) .
15 32. In furtherance of the conspiracy and to effect its object,
16 the following overt acts, among others, were committed within the
17 Southern District of California and elsewhere:

18 a. In or about September 17, 2012, AZANO met Candidate 2

19 for dinner in downtown San Diego.

20 b. In about August and September, 2012, AZANO, CORTES, and

21 Encinas discussed how best to support Candidate 2's and

22 Candidate 3's campaigns.

23 c. In or about September 2012, AZANO, accompanied by

24 Encinas, instructed Chase to make certain large

25 contributions in support of Candidates 2 and 3.

26 //
27 //
28 //
14
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1 d. On or about September 24, 2012, at AZANO's direction,

2 Chase wrote a $30,000 check to a political party

3 committee associated with Candidate 2' s campaign for

4 federal office.
5 All in violation of Title 18, United States Code, Section 371.
6 Count 3: Donation and Contribution by a Foreign National
7 (2 USC §§ 437g (d) (1) (A) and 441e (a) (1) (A) & 18 USC § 2)

8 33. Paragraphs 1 through 25 of this Indictment are realleged and

9 incorporated by reference.
10 34. From in or about May 2012 through in or about November 2012,
11 within the Southern District of California, defendants JOSE SUSUMO
12, AZANO MATSURA, aka Mr. A., aka Mr. Lambo, RAVNEET SINGH, aka Ravi
13 Singh, ELECTIONMALL, INC., MARCO POLO CORTES, and EDWARD SUSUMO AZANO
14 HESTER, aka Susu, aka Junior, knowingly and willfully did, directly
15 and indirectly, make contributions and donations of a foreign national
16 aggregating at least $25,000 during a calendar year in connection with
17 Federal and local elections - to wit,
18 a. by donating $100,000 of AZANO'S money to an independent
19 expenditure committee that supported Candidate l's
20 campaign for the office of Mayor of San Diego during

21 the 2012 primary election cycle;

22 b. by donating at least $75,000 of services to

23 Candidate l's campaign for the office of Mayor of

24 San Diego during the 2012 primary election cycle, as

25 financed by AZANO;

26 c. by contributing $30,000 of AZANO's money to a political

27 committee that supported candidates for federal office;

28 II
15
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1 d. by donating $120,000 of AZANO's money to an independent

2 expenditure committee that supported Candidate 3's

3 campaign for the office of Mayor of San Diego during

4 the 2012 general election cycle;

5 e. by making a donation of $30,000 to a political

6 committee that supported Candidate 3's campaign for the

7 office of Mayor of San Diego during the 2012 general

8 election cycle; and

9 f. by donating services worth approximately $191,955,

10 financed by defendant AZANO to Candidate 3' s campaign

11 for the office of Mayor of San Diego during the 2012

12 general election cycle;

13 all in violation of Title 2, United States Code,

14 Sections 437g(d) (1) (A) and 441e(a) (1) (A) (recodified at Title 52,
15 United States Code, Sections 30109 (d) (1) (A) and 30121 (a) (1) (A)), and
16 Title 18, United States Code, Section 2.
17 Count 4: Contribution in the Name of Another
18 (2 USC §§ 437g(d) (1) (A) and 44lf & 18 USC § 2)
19 35. Paragraphs 1 through 25 of this Indictment are realleged and
20 incorporated by reference.
21 36. On or about September 24, 2012, within the Southern District
22 of California and elsewhere, defendants JOSE SUSUMO AZANO MATSURA, aka
23 Mr. A., aka Mr. Lambo, and MARCO POLO CORTES knowingly and willfully
24 made a contribution in the name of another person aggregating at least
25 $25,000 during a calendar year in connection with Federal elections -
26 to wit, by contributing $30,000 of defendant AZANO's money in Marc
27 Chase's name to a committee of a political party supporting federal
28 candidates; all in violation of Title 2, United States Code,
16
 Case 3:14-cr-00388-MMA Document 336 Filed 07/08/16 PageID.2357 Page 17 of 23
, .'

1 Sections 437g(d) (1) (A) and 44lf (recodified at Title 52, United States
2 Code, Sections 30109(d) (1) (A) and 30122), and Title 18, United States
3 Code, Section 2.
4 Counts 5-37: Falsification of Records Related to Campaign Finance
5 (18 USC §§ 1519 & 2)
6 37. Paragraphs 1 through 25 of this Indictment are realleged and
7 incorporated by reference.
8 38. On or about the dates below, within the Southern District of
9 California and elsewhere, defendants JOSE SUSUMO AZANO MATSURA, aka
10 Mr. A., aka Mr. Lambo, RAVNEET SINGH, aka Ravi Singh, ELECTIONMALL,
11 INC., MARCO POLO CORTES, and EDWARD SUSUMO AZANO HESTER, aka Susu, aka

12 Junior, as set forth below, knowingly concealed, covered up,

13 falsified, and made a false entry in a record and document with the
14 intent to impede, obstruct, and influence the investigation and proper
15 administration of matters within the jurisdiction of the Federal
16 Bureau of Investigation, and in relation to and in contemplation of

17 such matters to wit, by concealing and covering up, in records

18 specified below, the fact that defendant AZANO was the true source of

19 the following campaign donations and contributions:

20 II
21 II
22 II
23 II
24 II
25 II
26 II
27 II
28 II
17
 Case 3:14-cr-00388-MMA Document 336 Filed 07/08/16 PageID.2358 Page 18 of 23

COUNT DATE DEFENDANTS RECORD APPROX. FALSELY

1 AMOUNT REPRESENTED TO
BE MADE BY
2
5 12/29/11 AZANO San Diego City $1000 A.G. and L.G.
3 Clerk's Record
of Donations to
4 Candidate 1
6 12/29/11 AZANO; San Diego City $500 J.W.
5 E.S. AZANO Clerk's Record
of Donations to
6
Candidate 1
7 7 12/29/11 AZANO; San Diego City $500 P.M.
E.S. AZANO Clerk's Record
8 of Donations to
Candidate 1
9 8 12/29/11 AZANO; San Diego City $500 M.K.
E.S. AZANO Clerk's Record
10
of Donations to
11 Candidate 1
9 12/29/11 AZANO; San Diego City $500 M.G.
12 E.S. AZANO Clerk's Record
of Donations to
13 Candidate 1
10 12/29/11 AZANO; San Diego City $500 B.D.
14
E.S. AZANO Clerk's Record
15 of Donations to
Candidate 1
16 11 12/29/11 AZANO; San Diego City $500 R.L.
E.S. AZANO Clerk's Record
17 of Donations to
Candidate 1
18
12 12/31/11 AZANO; San Diego City $500 M.N.
19 E.S. AZANO Clerk's Record
of Donations to
20 Candidate 1
13 12/29/11 AZANO; San Diego City $500 loD.
21 E.S. AZANO Clerk's Record
of Donations to
22
Candidate 1
23 14 12/29/11 AZANO; San Diego City $500 J.G.
E.S. AZANO Clerk's Record
24 of Donations to
Candidate 1
25 15 12/29/11 AZANO; San Diego City $500 A.D.
E.S. AZANO Clerk's Record
26
of Donations to
27 Candidate 1

28
18
 .Case 3:14-cr-00388-MMA Document 336 Filed 07/08/16 PageID.2359 Page 19 of 23

COUNT DATE DEFENDANTS RECORD APPROX. FALSELY

1 AMOUNT REPRESENTED TO
BE MADE BY
2
16 12/29/11 AZANO; San Diego City $500 R.G.
3 E.S. AZANO Clerk's Record
of Donations to
4 Candidate 1
17 12/29/11 AZANO; San Diego City $500 B.H.
5 E.S. AZANO Clerk's Record
of Donations to
6
Candidate 1
7 18 12/29/11 AZANO San Diego City $500 Marc Chase
Clerk's Record
8 of Donations to
Candidate 1
9 19 12/29/11 AZANO San Diego 'City $500 R.C.
Clerk's Record
10
of Donations to
11 Candidate 1
20 12/29/11 AZANO San Diego City $500 O.F.
12 Clerk's Record
of Donations to
13 Candidate 1
21 12/29/11 AZANO San Diego City $500 L.Z.
14
Clerk's Record
15 of Donations to
Candidate 1
16 22 12/29/11 AZANO San Diego City $500 S.H.
Clerk's Record
17 of Donations to
Candidate 1
18
23 12/31/11 AZANO San Diego City $500 K.H.
19 Clerk's Record
of Donations to
20 Candidate 1
24 12/29/11 AZANO San Diego City $500 C.P.
21 Clerk's Record
of Donations to
22
Candidate 1
23 25 12/29/11 AZANO San Diego City $500 R.A.
Clerk's Record
24 of Donations to
Candidate 1
25 26 12/29/11 AZANO San Diego City $500 E.G.
Clerk's Record
26
of Donations to
27 Candidate 1

28
19
 Case 3:14-cr-00388-MMA Document 336 Filed 07/08/16 PageID.2360 Page 20 of 23
, I

COUNT DATE DEFENDANTS RECORD APPROX. FALSELY

1 AMOUNT REPRESENTED TO
BE MADE BY
2
27 12/29/11 AZANO San Diego City $500 T.G.
3 Clerk's Record
of Donations to
4 Candidate 1
28 12/29/11 AZANO San Diego City $500 W.N.
5 Clerk's Record
of Donations to
6
Candidate 1
7 29 12/29/11 AZANO San Diego City $500 S.N.
Clerk's Record
8 of Donations to
Candidate 1
9 30 1/2/12 AZANO San Diego City $500 Mi.p.
Clerk's Record
10
of Donations to
11 Candidate 1
31 1/2/12 AZANO San Diego City $500 Ma.P.
12 Clerk's Record
of Donations to
13 Candidate 1
32 February AZANO; San Diego City at least Unreported
14
2012 SINGH; Clerk's Record $75,000
15 ELECTIONMALL of Donations to
Candidate 1
16 33 5/2/12 AZANO San Diego City $100,000 Airsam N492RM,
Clerk's Record LLC
17 of Independent
Expenditure
18
Committees
19 Supporting
Candidate 1
20 34 9/24/12 AZANO; Federal $30,000 Marc Chase
CORTES Election
21 Commission's
Record of
22
Donations
23 35 9/27/12 AZANO; San Diego City $120,000 South Beach
CORTES Clerk's Record Acquisitions,
24 of Independent Inc.
Expenditure
25 .
Committees
Supporting
26
Candidate 3
27

28
20
 Case 3:14-cr-00388-MMA Document 336 Filed 07/08/16 PageID.2361 Page 21 of 23
, >

.
1 COUNT DATE DEFENDANTS RECORD APPROX. FALSELY
AMOUNT REPRESENTED TO
2
BE MADE BY
3 36 10/4/12 AZANO; California $30,000 West Coast
CORTES Secretary of Acquisitions,
4 State Record of LLC
Donations to
5 Political
Parties
6
37 October AZANO; San Diego City $191,955 Unreported
7 2012 SINGH; Clerk's Record
CORTES; of Donations to
8 ELECTIONMALL Candidate 3

9 All in violation of Title 18, United States Code, Sections 1519 and 2.
10 Count 38: Bribery

11 (18 USC §§ 201 (b) & 2)

12 39. Beginning in approximately December 2013 and continuing to

13 approximately January 2014, within the Southern District of California

14 and elsewhere, defendants RAVNEET SINGH, aka Ravi Singh, and
15 ELECTIONMALL, INC., directly and indirectly, corruptly gave, offered,

16 and promised a thing of value to a public official with the intent to

17 influence an official act and to induce that public official to do an

18 act and omit to do an act in violation of his lawful duties - to wit,

19 by offering and giving $1,000 to a federal official, O.M., a Special

20 Agent with the Federal Bureau of Investigation posing as an agent with

21 the Drug Enforcement Administration, in exchange for confidential and

22 classified information; all in violation of Title 18, United States

23 Code, Sections 201(b) and 2,.

24 //

25 //

26 //
27 //

28 //
21
 Case 3:14-cr-00388-MMA Document 336 Filed 07/08/16 PageID.2362 Page 22 of 23

1 Count 39: Alien in Possession of a Firearm

2 (18 USC § 922 (g) (5) (B))

3 40. Beginning on an unknown date and continuing up to on or

4 about January 22, 2014, within the Southern District of California and

5 elsewhere, defendant JOSE SUSUMO AZANO MATSURA, aka Mr. A., aka

6 Mr. Lambo, then being an alien admitted to the United States under a

7 nonimmigrant visa - and not having been admitted to the United States

8 for lawful hunting or sporting purposes, and not possessing any

9 hunting license or permit lawfully issued in the United States, and

10 not having received a waiver from the Attorney General knowingly

11 possessed in and affecting interstate commerce, a firearm to wit, a

12 black Sig Sauer P225 bearing serial number M634983, said firearm

13 having been shipped and transported in interstate commerce; in

14 violation of Title 18, United States Code, Section 922(g) (5) (B).

15 FORFEITURE ALLEGATIONS

16 41. Upon conviction of the offense alleged in Count 38 of this

17 Indictment, defendants RAVNEET SINGH, aka Ravi Singh, and

18 ELECTIONMALL, INC., shall forfeit to the United States all property,

19 real and personal, which constitutes or is derived from proceeds

20 traceable to the violation of Title 18, United States Code,

21 Section 201, including but not limited to $1,000; all in violation of

22 Title 18, United States Code, Section 981 (a) (1) (C), and Title 28,

23 United States Code, Section 2461(c).

24 42. If any of the above-described forfeited property, as a

25 result of any act or omission of defendants RAVNEET SINGH, aka Ravi

26 Singh, or ELECTIONMALL, INC., cannot be located upon the exercise of

27 due diligence; has been transferred or sold to, or deposited with, a

28 third person; has been placed beyond the jurisdiction of the Court;

22
 Case 3:14-cr-00388-MMA Document 336 Filed 07/08/16 PageID.2363 Page 23 of 23
r ,

1 has been substantially diminished in value; or has been commingled

2 with other property which cannot be subdivided without difficulty, it

3 is the intent of the United States, pursuant to Title 21,

4 United States Code, Section 853(p), made applicable herein by

5 Title 28, United States Code, Section 2461(c), to seek forfeiture of

6 any other property of the defendants up to the value of the property

7 described above subject to forfeiture.

8 43. Upon conviction of the offense alleged in Count 39 of this

9 Indictment, defendant JOSE SUSUMO AZANO MATSURA, aka Mr. A., aka

10 Mr. Lambo, shall forfeit to the United States, pursuant to Title 18,

11 United States Code, Section 924(d), and Title 28, United States Code,

12 Section 2461 (c) , all firearms and ammunition involved in the

13 commission of the offense, including but not limited to the following:

14 the black Sig Sauer P225 bearing serial number M634983, and all

15 ammunition found with it; all pursuant to Title 18, United States

16 Code, Sections 924 (g), and 981 (a) (1) (C), and Title 28, United States

17 Code, Section 2461(c).

18 DATED: July 8, 2016.

19 A TRUE BILL:
20

21 Foreperson

22 ALANA W. ROBINSON
Attorney for the United States
23 Acting Under Authority Conferred by Title 28,
United States Code, Section 515
24

25

26
27 HELEN H. HONG
Assistant U.S. Attorneys
28
23