IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF SOUTH CAROLTNA

COLUMBIA DIVTSION
UNITED STATES OF AMERICA
TAI{ES R. METTS
a/k/a
",fimmy
Metts"
a/k/a
"sheriff Metts,,
a/k/ a
"Lexingrton
Sheriff"
THE GRAND .JURY CHARGES:
At all t,imes rel_evant
otherwise stated:
1. Lexington County
friends t.o buy favors when
the identification and
al-iens.
NO. :
U. S. C.
S 371
U. S. C.
S 19s2
(a)
u. s. c. s r-s05
u. s. c.
s 1343
u. s. c.
s 1346
u.s.c.
s 132+(a)
U.S.C.
S 1324(a)
u.s.c.
s 2
INDTCTMENT
CR.
18
1B
18
18
18
8
8
1_8
(3)
(1) (A) (v) (r)
(1) (A) (iii)
t.o this Indictment, unLess
Sherif f ,JAMES R. METTS allowed
he accepted cash to int.erfere in
processing
of certain illegaI
A. Individuals Involved in the Criminal Sctreme
2 . The Def endant, .IAMES R. METTS, was and is the
Sherif f of Lexington County, Sout.h Carolina. METTS has
served as the Sheriff of Lexington County since L972. As
the Lexingt.on County Sherif f
,
METTS' of f icial duties
incLude overseeing county-wide law enforcement; running t.he
Lexington
count.y sherif f
,
s Department;
hiring, f iring, and
supervising
deputies and other department
empl0yees;
maintaining
records,- and coordinating
wit.h f ederal, sEate,
and ot,her local law enforcement.
As Lexington county
sheriff, METTS is ar-so responsibre
for operating the
Lexington County Detention
Center, which,
among other
things, accepts and houses individuals
arrested in and
around Lexington County.
3. From 2005 through 20L3, Danny Frazier served as a
member of the Lexington Town council_. As a favor, METTS
hired Frazier as an employee of t.he Lexington county
sherif f
's
Department to serve as a
,,business
riaison,, in
20L2.
4. Greg Leon was the owner and operator of severa]
Mexican restaurants in and around columbia, sc. rn at reast
20L1, Leon employed i11ega] ariens in those rest,aurants.
B. section ze1
G)
Federar rmmigration cooperat,ive
5. u.s. rmmigration and customs Enforcement. (rcE),
an
investigat.ive agency in the Department of Homeland security
(DHs)
,
'enforces
fed.eral immigration l-aws as part of its
homel-and security mission.
6. Section 287 (g)
of t,he Immigration
and Nationality
Act authorizes DHS to enter into written agreements with
local and state law enforcement
depart.ments (such
as a
sheri f f ' s department
) to aut.hori ze
.
the state or ]ocal
department' s officers
to perf
orm cert.ain Iimited
immigration functi-ons. This agreement is entered pursuant
to a
joint
Memorandum
of Agreement (MOA)
. Under a 287
(g)
MOA, ICE provides
certain law enforcement officers with t.he
t.raining, supervision,
and authorization to ident ify,
process,
and detain i1]ega1
al-iens they encounter within
their
jurisdictions
as part
of their l-aw-enforcement
activity. The purpose
of this corraboration is to enhance
the safety and security of communities by permitting
the
identification and processing
of arrested i1legal aliens so
that. t.hose who pose
a threat to public safety or a danger
to the communit.y can be removed.
7 . Designat.ed state or l-ocal- l-aw enforcement of f icers
under a Sect.ion 287
(g)
MOA become Task Force Of f icers wit.h
limit.ed immigration enforcement authority. rmmigration
enforcement activities conducted by these 297
(g)
Task Force
officers must be supervised and directed by rcE supervisory
officers
(r.e.,
an Enforcement Removal_ Officer
(ERO)
or
supervisory Deportation
Detention officer (sDDo)
)
.
Participating 2e7
(g)
Task Force Officers are not authorized
to perform
immigration
officer functions except when
working under the supervision and d.irect.ion of an rcE
supervisor. while a participating
l_ocal_ law enf orcement
depart,ment retains supervision
outside immigration
enforcement functions,
t.he l-ocal department lacks authority
to direct, control, or int.erf ere with a 297
(g)
Task Force
Officer' s immigration enforcement functions.
8. rn July of 20L0, METTS, and the Lexington county
Sherif f
's
Depart.ment, entered into a 287
(g)
MOA with ICE.
The Lexington 287
(g) program
began shortly t.hereaf ter and
was ful1y-st,af fed by early 2otl. under the 287
(g)
program,
certain Lexingt.on county of f icers received t.raining and
became 287
(g)
Task Force Of f icers
(also
known as Designat.ed
rmmigration officers) for rcE. These 287
(g)
Task Force
officers were granted limited immigration authority under
the 287
(g) program.
9. Under the Lexington 287
(g) program, the Ze7
(g)
Task Force officers were provided daily with a Foreign Born
Report, l-isting all potential
illegaI aliens who had been
arrested and placed in the Lexingt.on County Detention
center. These suspected foreign-born arrestees were then
screened to determine t.heir proper identificat.ion based on
biometric and biographical information. Properly
identif ying i11ega1 al-iens through the use of the
computerized rcE system
(referred
t.o as ENFoRCE/TDENT)
permits ICE to understand an al-ien, s immigration status in
t.he United States, to know t.he aLien's criminal- background,
and to track the al-ien in the f uture.
10. Pending this identity screening, l imited- t.erm
immigration hold or detainer was placed on each foreign-
born arrest,ee by the 287
(g)
Task Force Of f icers. Absent f CE
supervisory approval, alL suspected i1IegaI aliens were
required to be processed by the 287
(g)
Task Force Officers
through t.he ICE system
(ENFORCE/IDENT)
. Each arrestee that
was screened but not identified and processed as an i11ega1
alien was recorded in an Interview Log along with the
reason the arrestee was not identified and processed in the
ICE syst.em
(ENFORCE/IDENT)
. If an arrestee was ent.ered into
rcE system
(ENFORCE/TDENT)
,
then the 287
(g)
Task
officer would record that arrestee in the Detainer
Force
Log-
case Each entry into the Detainer Log included an fCE
number along with other information
about the arrestee and
the reason for his arrest.
11. Entering an i11ega1
arien into the rcE system
(ENFORCE/IDENT)
was a crucial step in the immigration
process.
Entry into the rcE syst.em included
the use of
TDENT, which permit,s
an analysis of t.he i1lega] arien,s
biometric information (
including
fingerprints
and
photographs)
to determine the t.rue identity of t.he i11ega1
al-ien as well- as biographical-
inf ormation such as
nationality, previous
criminar convictions, presence
on
terrorist watch 1ists, and prior immigration
encount.ers.
12. fn processing
an identified illegal arien, drr rcE
supervisor not a zel
G)
Task Force officer was reguired
to determine t,he appropriat.e immigration treatment of the
al-ien. Based on inf ormation f rom the rcE system
(ENFORCE/fDENT),
fCE determined whether the i11ega1 alien
had any aggravating circumstances
such as serious
criminaL convictions or prior
deportat.ions. If processing
aggravating
circumstances, then the alien coul-d be rel-eased by an rcE
supervisor and required to report to immigration officials
at a l-ater time. If the ICE system reveal-ed aggravating
revea]ed that, the al-ien lacked these
circumstances, then only an rcE supervisor courd require
t.hat. Ehe al-ien be detained beyond the time of the rimited
immigration ho1d.
13. Members of the Lexington County Sheriff, s
Department, including 287
(g)
Task Force Of f icers, l-acked
the aut.hority t.o circumvent the section 297(g) program. The
287
(g)
Task Force of f icers were required t.o enEer illegal
al-iens in the rCE system
(ENFORCE/TDENT)
. An iI1ega] al_ien
that was not entered into the rcE system
(ENFORCE/TDENT)
would not be identified and processed by ICE, and ICE wouLd
not l-earn if the iIIegaI al-ien. had aggravating
circumstances such as serious prior convictions.
C. Sheriff Metts Allowed Friends to Buy Favors when
Metts Accepted Cash in Return for Agreeing to
Assist Detained lllegal Aliens
1-4. Beginning in or around September of 20L!, METTS
agreed with Frazier and Leon to use his position, power,
and infl-uence t.o affect the identification and processing
of i1lega1 aliens held in the Lexington County Detention
Cent.er. Based on that. agreement, METTS directed and
interfered, and attempted to direct. and int,erfere, with the
immigrat.ion enforcement activities of DHS, ICE, and the
Lexington County officers serving as 2e7
G)
Task Force
officers. rn return for his agreement and assistance, METTS
accepted cash payments.
15. When METTS was informed of an arrest and detent,ion
of an i1Iega1 al-ien working for Leon, METTS wourd contact
his command staf f and other employees to
j_nstruct
that
preferential-
t,reatment be provided
to those specific
i11ega] aLiens. rn doing So, METTS was aware t.hat Leon, s
employees were i11ega1 aliens. For example:
a. On l-ate Friday night., September 2
,
207_1_,
Il1egal
#f an illega1 aLien employed by Leon
was arrested by West Columbia
police
Department and transported to the Lexington
County Detention Center, arriving on September
3. At t.he detention cenLer, a 287
(g)
Task Force
Officer placed
an immigration hold on l11ega1
#f. After Labor Day, on Tuesday, September 6,
201,1, dt around 2:27pm, Danny Frazier used his
cellphone to contacE. METTS on his cellphone.
After the approximately nine minute cal-I with
METTS, Frazier then used his cellphone to call
Greg Leon at approximately 2:36pm. At 3:01pm,
METTS' then used his cellphone t,o cal-I Frazier
b.
on his cellphone
for an approximately five-
minut.e cal1. Then Frazier used his cellphone to
cal-l Leon on his cellphone at 3 : 09pm. During
Ehese caLl-s and otherwise, Frazier inf ormed
METTS t.hat one of Leon,s employees I11ega1
#f
had been arrested and sent t.o the Lexington
County Detention Center. METTS agreed to assist,
with the i1IegaI al-ien. METTS subsequently
informed Frazier that a hotd had already been
placed
on f1lega1
#f and. instructed Frazier
that Leon needed t.o be quicker in provid.ing
METTS with notice of an i11ega1 aLien, s arrest.
In return f or METTS, agreement and att.empted
assist.ance, METTS accepted cash from Frazier
that. had been provided
by Leon.
On Friday night., September 16, 2OLL, Illegal
#Z
an i11egaI al-ien employed by Leon was
arrested by West. Col-umbia
police
Department and
t.ransported to Lexington County Detention
Center. On the morning of September 17
,
201,1
,
Leon used his cellphone to contact. Frazier.
Af t,er Frazier and Leon spoke on their ceI1
phones
at approximately 9:42am, Frazier used
his cellphone to contact METTS on his cellphone
at 9:48am. At approximately 9:52am, METTS then
used his cellphone to call_ the Lexington County
Sheriff's Department at 803-785-2400. Shortly
thereaf ter, at l-0 : O7am, a member of the
Lexington Count,y Sheriff
,
s Department command
st,aff used his cellphone to call METTS on his
celI phone. METTS then caLl-ed Frazier back via
cellphone at approximat.ely 10:11-am and then
immediately t.hereafter METTS called back to the
member of the Lexington County Sheriff, s
Department command staff. Frazier then cal_led
Leon at. L0:15am. During t.hese ca1ls and
ot.herwise, Leon asked Frazier to contact METTS
about f1Iega1
#2's arrest and incarceration at
Lexingt.on County Detention Center. METTS agreed
t.o assist with lllega1
#2. PeT METTS,
not fu11y interventJ-on,
ident.i f ied,
rllegal
#Z
was
entered into the ICE system
(ENFORCE/IDENT)
, or processed to determine t.he
appropriate immigration treatment. fnstead, the
10
immigration
hold was removed and rrlegal
#z was
rel-eased wit,hout. being identified or processed
by ICE. In return for METTS, agreement,,
assistance, and attempted. assistance, METTS
accepted cash f rom Frazier t,hat had been
provided
by Leon.
c. On Tuesd.ay af ternoon, November B, 20]11,, f 1lega1
#g an i1IegaI alien employed. by Leon was
arrested by west columbia
po]ice
Department. and.
transport,ed to Lexingt.on Count.y Detention
Cent.er . On November 8 - 10
,
207-1_
,
Fraz ier used
his cel-I phone
to communicate with Leon, METTS,
and a member of METTS, Lexington County Sheriff
Department command staff on their respective
cellphones about f 1IegaI
#3. During these call_s
and ot.herwise, they discussed having I1Iega1
#:
released and METTS agreed to assist. fn return
for METTS' agreement. and attempted assistance,
METTS accepted cash.
d. On Sunday morning, November 13, 2oll, fllegal
#+ an i1Iega1 alien employed by Leon was
arrested by West Columbia
police
Department and
11
transported to Lexington County Detention
Center. On Monday, November a4
,
201,1,, dL
approximately 9:25am
,
Frazier ca1led METTS
concerning I1IegaI
#q. METTS t.old Frazj-er t.o
contact a cert.ain member of the Lexington
Count,y Sheriff Department command staff on his
cellphone. At 9:35am, Frazier cont.acted the
member of the Lexington County Sheriff
Department command staff on his cellphone. At
9:51am, the same member of t.he Lexington County
Sheriff Depart,ment command staff call_ed Frazier
on his cellphone. Ihen, dt 1-O:26am, Frazier
called Leon on his cellphone. At 11:31am and
L2:0 5pm, Leon called METTS on his cellphone.
Leon met with METTS at. the Lexington County
Sherriff's Department; during this meetirg,
METTS accepted an envelope with cash in return
for METTS' agreement, assistance, and attempted
assistance with i1IegaI aliens employed by
Leon, including I11egaI #q. Based on the
int,ervention of MET'fS, and his staf f
,
I11ega1
#q was not fuIIy identified, ent,ered into the
L2
ICE system
(ENFORCE/fDpUf),
or processed
to
determine the appropriate immigration
treatment.. Instead, the immigration hold was
removed and I11ega1
#+ was rel_eased without.
being identified
or processed by ICE.
COI'IiIIT 1
(conspiracy
to violate Federal Law and rnterfere with
Government function)
]-6. The allegations set forth in paragraphs 1 t.hrough
1-5 are repeat.ed and realleged as if set. forth ful1y herein.
1,7. At times unknown to the grand jury,
but beginning
at least in or around September 201,L, and continuing
thereaf Ler, up to and including the dat.e of this
Indictment, in t.he District of South Carolina, the
Defendant METTS, Danny Frazier, Greg Leon, and others known
and unknown knowingly
conspired, confederated,
understanding
and intentionally combined,
agreed, and had a tacit
a. tso eommit the offense of Use of an Interstate
Facility to Facilitate Bribery: Lhat is, to use
a cellphone
(i.e.,
a facility in interstate
commerce), with intent to promote, establish,
13
carry oD, and facilitate
an unlawful activity,
to wit. bribery in viol_ation
of the l_aws of
South Carolina (SC
Code
SS8-13-705 and 16_9_
220)
,
and t.hereaf ter perf ormed and. attempted to
perform
an act to promot.e,
establish, carry orf
,
and facilitat.e the bribery, in violation of
Titl-e 18,
7es2 (a) (3
) ;
United Stat.es Code, Section
b. tso commit the offense of Use of fnterstate
Wires to Further Scheme to Defraud Citizens of
Lexington County of their Right to Honest
Services: that is, to devise and int.end to
devise a scheme and art.if ice to def raud t.he
citizens of Lexington County, South CaroLina,
of their right to the honest services of the
Sherif f of Lexington County t,hrough bribery,
and transmitted and caused to be t.ransmit.ted by
means of wire communication in interstate
commerce signals, signs, and sounds for the
purpose of executi-ng such scheme and artifice,
in vioLation of Title 18
,
United Stat.es Code,
Sections 1343 and 1-346;
l4
c. Eo commit the offense of obstructing
Proceedings
before united states Department of
Homeland Security:
that is, to corruptly
influence, obstruct, and. impede, and endeavor
to influence,
obstruct, and impede the due and
proper
administration
of the ]aw under which a
pending proceeding
to ident,if y and process
iIlegal aliens was being had before t,he united
States Department
of Homel_and Security, in
viol-ation of Titl_e 1g
,
United States Cod.e,
Section 1505;
d. to impede, impair, defeat, and obstruct t,he
identification
and processing
of iIIegaI aliens
by the UniEed StaEes and DHS: that is, to
defraud t.he United States and an agency of the
United St,ates in the exercise of ]awf ul_
government. functions .
Purposes of the Conspiracy
L8. rt was a purpose
of the conspiracy for Defendant
METTS to enrich himsel-f by using and agreeing to use his
official position, power,
and infl-uence in exchange for
cash.
15
19. It was a
purpose
of the eonspiraey for Defendant
METTS t.o enrich ot.hers by corruptly and knowingly using
METTS'position, power, and influence to obtain special
treat.ment. for certain known i1]ega1 aLiens secured in the
Lexington County Detent.ion Center.
20. It. was the purpose
of the conspiracy for Defendant.
METTS to use his position, power, and infl-uence to obtain
special treatment for METTS' frj-ends.
21,. ft was a purpose
of the conspiracy for Defendant
METTS and others to conceal the i1Iega1 cash payments
received by METTS.
22. It was a purpose of the conspiracy for Defendant
METTS and ot.hers to conceal- METTS' improper use of the
posit,ion, power, and inf luence as Sherif f .
23. It was a purpose of the conspiracy for Defendant
METTS to use METTS '
pos it ion, power
,
and inf l-uence to
obtain special treatment for cert.ain iI1egaI aLiens secured
in the Lexington County Detention Center.
24. It was a purpose the conspiracy that Defendant
METTS and his co-conspirators to impede, impair, defeat,
and obstruct t.he lawful government functions of DHS in the
identification and
processing of i11ega1 al-iens.
1,5
25.
but were
The
not
a.
Manner and Means of the Conspiraey
manner and means of the conspiracy included,
limit.ed to, the following:
Def endant METTS, while serving as the el_ected
Sheriff of Lexington County, accepted,
received, and agreed to accept and receive,
things of value and promises to supply things
of vaLue, Lo wi-t, cash, from Leon and Frazier.
Def endant. METTS t,ook st.eps to conceal the
improper use of METTS'position, power, and
influence and the payments received from
Frazier and Leon in order to hide the nature
and scope of his deal-ings wit.h Frazier and
Leon.
Defendant METTS engaged in official- actions as
Lexingt.on County Sherif f
,
and improperly used
the power and influence of his position as
Sheriff including intervening in the Section
287
(g)
immigrat,ion enforcement program operated
by the Lexington County Sheriff's Department
and the Lexington County Detention Center on
behal-f of and benefiting Greg Leon, known
b.
c.
L7
ilIegaI aliens, and restaurants that employed
i11egaI al-iens.
d. Defendant METTS obstructed, impeded, impaired,
and defeated the lawful- government funct.ions of
the DHS in the identification and processing of
i1Iega1 aliens.
Overt Acts in Furtherance of the Conspiracy
26. In furtherance of the conspiracy and to achieve
its purposes, the Defendant METTS, Danny Frazier, Greg
Leon, and others known and unknown committed the following
overt acts, amongi others described above in Paragraph 15,
in the District of South Carolina:
On September 2, 201L, I11ega1 #f was arresEed in West
Columbia; the following overt acLs were done by members
of this conspiracy in rel-aEion to his arrest:
a. Leon spoke with Frazier and asked if Frazier
could assist in getting an employee who was an
i11ega1 alien rel-eased f rom Lexingt.on County
Detention Center.
b. After Labor Ddy, on Tuesday, Sept.ember 6, 201-L,
Frazier spoke wit.h METTS and discussed METTS
assist,ing with providing special treatment for
18
an ilIega1
alien detained in the Lexington
County Detention
Cent.er. Frazier explained that
the i1Iega1 alien was employed. by Leon and. t,hat
Leon woul-d be generous (r.e.,
make payment.s) in
ret.urn for METTS, assistance. METTS agreed.
METTS checked wit.h his staff to determine the
status of the i11egaI alien in the d.et.ention
center and to provide what special treatment
METTS couLd provide
After speaking with his staff, METTS contacted
Frazier to instruct Frazi_er t.hat METTS needed
to be informed of the detention of i11egaI
a1iens quicker in order to best provide
special
treatment. to those i1Iega1 al_iens.
e. Leon provided Frazier with money for Frazier to
del-iver to METTS. Frazier delivered. cash t.o
METTS, which METTS accepted, in return for his
agreement. and at.t.empted assistance with the
i1IegaI alien.
On September A6, 201-L, fIIegal
#Z was arrested in West
Col-umbia; the following overt acts were done by members
of this conspiracy in relation to his arrest:
d.
19
f . On Saturday morning, September 17
,
2Ot1_, Leon
cal-1ed Frazier
Eo discuss Frazi-er contacting
METTS about assisting with an ilregal alien
arrested the night before and placed.
in the
Lexington County Detent.ion Cent.er.
g. Frazier calIed METTS and. discussed METTS
providing
special treatment for the i11ega1
alien.
METTS spoke with his staff about providing
special treatment, for t.he i1Iega1 al_ien.
Shortly after these conversations and according
to METTS' direction, a member of METTS
,
st.af f
h.
l_.
j
removed the hold previously placed
iIIegaI alien.
the
Approximately
a week Iat.er, Leon provided.
Frazier wit.h money f or Frazier to deliver to
METTS. Frazier then del-ivered cash to METTS,
which METTS accepted, in return for his
agreement, assj-stance, and attempted assistance
wit.h t.he i11ega1 al_ien.
20
On November 8, 2011, Illegal #3 was arrested in West
CoLumbia; the following overt acts were done by members
of this conspiracy in relation to his arrest:
k. On November 8-9, 201L, Leon spoke with Frazier
to discuss Frazier cont.acting METTS about.
assist.ing wit.h an i1Iega1 alien arrested on
Tuesday aft.ernoon and placed in Ehe Lexington
County Detention Cent.er.
1. On Wednesday November 9
,
201-L, Frazier spoke
with METTS and a member of METTS' command staff
about providing special treatment for the
illegal alien.
m. On November 10
,
2071
,
Frazler spoke wit.h a
member of METTS' command staff about providing
special t,reatment for the i11ega1 al-ien.
On November 13, 20LL, If1egal #q was arrested in West
Columbia; t.he following overt act.s were done by members
of this conspiracy in relat.ion to his arrest:
n. On Monday, November 14, 20LL, Frazier contacted
METTS about an iIlegal alien arrested and.
placed in the Lexington County Detention
Center.
2t
p.
o. Per METTS' instruetion, Frazier then called a
member of METTS' command staff to discuss
obt.aining special treatment for t.he i11ega1
al-ien.
After speaking with Sheriff DeparLment staff
about the iI1egaI alien, the member of METTS'
command staff called Frazier back. Shortly
thereaf ter, Frazier call-ed Leon.
Around l-uncht
j-me,
Leon called METTS directly
and arranged to meet METTS at the Lexington
County Sherif f 's Department. At that meet
j-ng,
Leon provided and METTS accepted an envelope
with cash in return for METTS' agreement,
assistance, and attempted assistance with
illegal al-iens,
j-ncluding
the alien arrested on
November 13, 20L1,.
r . Based on t.he int,ervention of METTS, and his
staff, Illegal #+
was not fuIly identified,
entered into the IcE system
(ENFoRCE/TDENT), or
processed to determine the appropriate
immigration treatment. Inst.ead, the immigration
q.
22
hold was removed and lllegal
#4 was released
without being identified or processed
by ICE.
All in viol-ation of Title 18, United Stat.es Code,
Section 37]-.
couMrs 2 -5
(Use
of Interstate Faeility to Facilitate Bribery)
27 . The allegat.ions set forth in paragraphs 1 t,hrough
26 are repeated and real-Ieged as if set forth fu11y herein.
28. On or about the respective dates seE forth beIow,
in the District of Sout,h Carol-ina, t.he Def endant METTS,
Danny Frazier
,
Greg Leon, and ot.hers known and unknown used
a f acility in int,erstat.e commerce, wit.h intent to promote,
establish, carry oD, and facilitat.e unl-awful act.ivit,y; to
wit,
a. bribery in viol-ation of SC Code S8-l-3-705; that
is, METTS, directly and indirectly, knowingly
accepEed, received, and agreed to receive
something of val-ue as a public of f icial in
South Carolina for himseLf and another in
return for being influenced in the discharge of
his of f icial- responsibilities; and
23
b. bribery in violation of SC Code 516-9-220;
that
is, METTS corruptty accepted something of value
and a promise to supply something of value as
an officer in South Carol-ina for his benefit in
exchange for the improper use of Lhe power of
his position as Sheriff;
and thereafter
performed and attempted to perform acts to
promote, establish t
canrl^y OD, and faciLit.ate the unlawful
activity.
Count Dates
Description
2 Sept. 6, 20lL Used cellular
Phones
to
communicate followed bY METTS'
intervention in the SecEion
287
(g) immigration enforcement
program and accePt.ance of cash in
return
3 Sept..1,7, 207-L Used celluIar
Phones
to
communicate folfowed bY METTS'
intervention
in the Section
287
(g) immigrat.ion enforcement
program and accePtance of cash in
return
4
5
Nov. 9
,
20Ll Used cellu1ar
Phones
to
communicate
f o1l-owed bY METTS'
intervention
in the Section
287
(g) immigration enforcement
program and acceptance of cash in
return
Nov. !4
,
201,1 Used cellu1ar
Phones
to
communicate
followed bY METTS'
intervention
in Ehe Section
287
(g) immigration
enforcement
program and. accePtance
of cash in
return
24
A11 in violat,ion of Title 18,
Sections ]-952
(a) (3)
and 2.
Unit,ed States Code,
corr}flrs 6 - 9
(Use
of Int,erstate Wire to Defraud the Citizens of
Lexington County of Their Right to Honest Services)
l-. The allegations set f orth in paragraphs 1- through
26 are repeated and real-Ieged as if set forth fu11y herein.
2. On or about the respective dates shown below, in
the District of South Carolina, the Defendant METTS, Danny
Frazier, Greg Leon, and others known and unknown, having
d.evised and intending to devise a scheme and art.if ice t.o
defraud, and to deprive Lexington County, South Carolina,
and it,s citizens of their intangible right to METTS' honest
services as the Sheriff of Lexington County through
bribery, knowingly and intentionally transmitted and caused
to be transmitted by means of wire communication in
int.erstate commerce signals, signs, and sounds f or t.he
purpose of executing such scheme and artifice -
25
Count Dates Description
6 Sept. 5, 20lL Used cellular phones Lo
communicate followed by METTS'
intervention in the Section 287
(g)
immigration enforcement program
and acceptance of cash in ret.urn
7 Sept.17, 201-1- Used cel-luLar phones t.o
communicate followed by METTS'
intervent.ion in the Section 287
(g)
immigration enforcement program
and accepEance of cash in ret.urn
B Nov. 9
,
20LL Used ceLlular phones to
communj.cate f ol-lowed by METTS'
intervention in the Section 287
(g)
immigration enforcement program
and acceptance of cash in return
9 Nov. L4
,
201-1- Used celluIar phones to
communicate f oLl-owed by METTS'
intervention in the Section 287
(g)
immigration enforcement program
and acceptance of cash in return
A11 in violation of Tit.le 18
,
Unit,ed States Code,
Sections 1,343
,
1346, and 2.
26
eorrllT L0
(Conspiracy
to Harbor ll1ega1 aliens)
3. The allegations set forth in paragraphs 1 Ehrough
26 are repeated and realleged as if set. forth fuIIy herein.
4. At times unknown to the grand jury,
but beginning
at. least in or around September 201"1,, and cont.inuing
thereaf ter, up t.o and including the date of this
Indictment, in the District of South Caroli-na, the
Defendant. METTS, Danny Frazl-er, Greg Leon, and others known
and unknown knowingly and intentionally combined,
conspj-red, conf ederated, agreed, and had tacit
understanding to vio]ate Sect ion ]-324
(a) (
1)
(A) (iii
) of
Tit.le 8 of the united stat.es code; that is, to harbor,
conceal, and shield from detection, and atLempt to harbor,
conceal-, and shield f rom detection, an a1ien knowing, and
in reckless disregard of the fact, that the a]ien had come
Lo, entered, and remained in the United States in violation
of l-aw.
A11 in violation of Tit1e 8,
Section 1,324
(a) (1) (A) (v) (I)
.
United States Code,
27
"
BiI]
WILLTAM N. NETTLES (JnT)
UNTTED STATES ATTORNEY
28