Case 1:10-cr-00134-WSD-LTW Document 55 Filed 09/21/10 Page 1 of 4
FILE S INNI CHAMBERS
IN THE UNITED STATES DISTRICT COURT
SEP 2 1 2010
FOR THE NORTHERN DISTRICT OF GEORGIA
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.... DAM E T NCI
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Q ATLANTA DIVISION By e puty Clerk
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V UNITED STATES OF AMERICA
. .---- CRIMINAL INDICTMENT
L..6 V .
NO . 1 :10-CR-134-WSD
DONALD E . FRANK (Second Superseding
Indictment)
THE GRAND JURY CHARGES THAT :
COUNT ONE - BRIBERY
In or about mid-September 2008, in the Northern District of
Georgia, defendant, DONALD E . FRANK, then a Deputy Chief of Police
with the DeKalb County Police Department, an agency which received
in a one year period benefits in excess of $10,000 under a federal
program, did corruptly solicit and demand for the benefit of any
person, and accept and agree to accept something of value from Amin
Budhwani, intending to be influenced and rewarded in connection
with the business, transaction, and series of transactions of said
Police Department involving something of value of $5,000 or more,
all in violation of Title 18, United States Code Section
666 (a) (1) (B) .
Case 1:10-cr-00134-WSD-LTW Document 55 Filed 09/21/10 Page 2 of 4
COUNT TWO - BRIBERY
On or about October 14, 2008, in the Northern District of
Georgia, defendant, DONALD E . FRANK, then a Deputy Chief of Police
with the DeKalb County Police Department, an agency which received
in a one year period benefits in excess of $10,000 under a federal
program, did corruptly solicit and demand for the benefit of any
person, and accept and agree to accept something of value from Amin
Budhwani, intending to be influenced and rewarded in connection
with the business, transaction, and series of transactions of said
Police Department involving something of value of $5,000 or more,
all in violation of Title 18, United States Code Section
666 (a) (1) (B) .
COUNT THREE - BRIBERY
From on or about October 20 through October 27, 2008, in the
Northern District of Georgia, defendant, DONALD E . FRANK, then a
Deputy Chief of Police with the DeKalb County Police Department, an
agency which received in a one year period benefits in excess of
$10,000 under a federal program, did corruptly solicit and demand
for the benefit of any person, and accept and agree to accept
something of value from Amin Budhwani, intending to be influenced
and rewarded in connection with the business, transaction, and
series of transactions of said Police Department involving
2
Case 1:10-cr-00134-WSD-LTW Document 55 Filed 09/21/10 Page 3 of 4
something of value of $5,000 or more, all in violation of Title 18,
United States Code Section 666(a)(1)(B) .
COUNT FOUR - BRIBERY
On or about August 12, 2009 in the Northern District of
Georgia, in the Northern District of Georgia, defendant, DONALD E .
FRANK, then a Deputy Chief of Police with the DeKalb County Police
Department, an agency which received in a one year period benefits
in excess of $10,000 under a federal program, did corruptly solicit
and demand for the benefit of any person, and accept and agree to
accept something of value from Amin Budhwani, intending to be
influenced and rewarded in connection with the business,
transaction, and series of transactions of said Police Department
involving something of value of $5,000 or more, all in violation of
Title 18, United States Code Section 666(a)(1)(B) .
COUNT FIVE - BRIBERY
On or about August 20, 2009 in the Northern District of
Georgia, in the Northern District of Georgia, defendant, DONALD E .
FRANK, then a Deputy Chief of Police with the DeKalb County Police
Department, an agency which received in a one year period benefits
in excess of $10,000 under a federal program, did corruptly solicit
and demand for the benefit of any person, and accept and agree to
accept something of value from Amin Budhwani, intending to be
3
d
Case 1:10-cr-00134-WSD-LTW Document 55 Filed 09/21/10 Page 4 of 4
influenced and rewarded in connection with the business,
transaction, and series of transactions of said Police Department
involving something of value of $5,000 or more, all in violation of
Title 18, United States Code Section 666(a)(1)(B) .
A BILL
"I ~7
FOR PERSON
SALLY QUILLIAN YATES
UNITED STATES ATTORNEY
SUSAN COPPEDGE
ASSISTANT UNITED STATES ATTORNEY
Georgia Bar No . 187251
404/581-6250
404/581-6181 (facsimile)
~_.
CHRISTOPHER BLY
ASSISTANT UNITE STATES ATTORNEY
Georgia Bar No . 064634
600 U .S . Courthouse
75 Spring Street, S .W .
Atlanta, GA 30303
404/581-6048