The Indictment - The Text

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION
UNITED STATES OF AMERICA
v.
LAURA JORDAN (1) a/k/a Laura Maczka MARK JORDAN (2)
§ § SEALED {T l § No. 4:18CR P l
§
INDICTMENT THE UNITED STATES GRAND JURY CHARGES: MAY 1 0 2018
Count O e Cleric, US. District Ccmrt Texas Eastern
Violation: 18 U.S.C. § 1349 (Conspiracy to Commit Honest Services Wire Fraud in violation of 18 U.S.C. §§ 1343,1346)
A. Introduction
At all times material to this Indictment:
1. The City of Richardson, Texas ( City of Richardson  or “the City”), was a
local government and political subdivision of the State of Texas and was governed by a
mayor and a city council.
2. Laura Jor an, defendant, who at all relevant times was known as Laura
Maczka and will thus be referred to as “Maczka” in this Indictment, was the mayor of
the City of Richardson from May 2013 through April 2015. As mayor, Maczka was an
agent of the City of Richardson and a voting member of the Richardson City Council.
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Additionally, Maczka owed a fiduciary duty to the citizens of the City to perform the
duties and responsibilities of her office free from corrupt influence.
3. Maczka s duties as mayor included voting, along with the other members
of the Richardson City Council, on proposals for zoning changes within the limits of the
City. She also voted on requests to authorize the City Manager of the City of Richardson
to negotiate contracts with land developers to reimburse land developers, with
government funds, for expenses incurred on developments within the City.
4. Maczka earned $50 per meeting as mayor of the City of Richardson. In
2013 and 2014, Maczka earned approximately $2,600 each year working for the City of
Richardson.
5. Mark Jordan ( Jordan ), defendant, was a commercial real-estate
developer. One of his companies, JP Realty Partners LLC (“JP Partners ), acquired and
developed commercial real estate. In 2011, JP Partners, along with a separate entity,
KBS Strategic Opportunity REIT Richardson Portfolio JV, LLC, formed JP-KBS
Richardson Holdings, LLC. JP-KBS Richardson Holdings, LLC, with Jordan acting as
managing partner, purchased approximately 40 acres of developable land, along with two
office properties (collectively called the “Palisades Property”), located in the City of
Richardson, the majority of which was located in the Eastern District of Texas. The
Palisades Property was adjacent to the Canyon Creek and Prairie Creek neighborhoods in
Richardson, Texas. Jordan also owned and controlled Sooner National Property
Management, LP.
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6. The Development and Economic Development Agreement request ( DEDA
Request ) was a request Jordan caused to be submitted to the City of Richardson that
requested up to $47,000,000 in reimbursements for construction and infrastructure
expenses related to the Palisades Property, which included a 25-year, 50% tax rebate for
infrastructure costs.
7. Maczka controlled a Wells Fargo bank account ending in 1020 ( Wells
Fargo account 1”). Maczka also controlled a Wells Fargo bank account ending in 4928
(“Wells Fargo account 2”).
8. “The Contractor” was an individual known to the Grand Jury. The
Contractor owned and operated “the Company,” which was located in McKinney, Texas,
in the Eastern District of Texas. The Company was also known to the Grand Jury.
9. “The Employee” was an individual known to the Grand Jury. The
Employee worked for Sooner National Property Management, LP as a leasing agent from
in or around 2012 through in or around February 2015.
10. JJ, MM, GS, GK, LG, and JS were individuals known to the Grand Jury. JJ
worked for Sooner National Property Management, LP as a Human Resources manager.
MM was Maczka s husband from on or about April 22, 1989, through on or about
January 8, 2015. The City of Richardson hired GS, an attorney, to conduct an ethics
investigation into Maczka s and Jordan’s relationship in Spring 2015. JS was an
attorney Maczka retained to respond to the City s ethics investigation in Spring 2015.
LG was Jordan’s architect who spoke on Jordan’s behalf at City meetings concerning
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the Palisades Property. And GK was Jordan s accountant who filed Jordan’s tax
returns.
B. The Conspiracy
11. From in or around May 2013, through on or about July 31,2015, in the
Eastern District of Texas and elsewhere, Maczka and Jordan conspired, combined, and
agreed to devise a scheme and artifice to deprive the citizens of the City of Richardson,
through fraud, of the honest services of Maczka, the mayor of the City of Richardson,
and, for the purpose of executing the scheme and artifice, caused a wire communication
to be transmitted in interstate commerce, a violation of 18 U.S.C. §§ 1343 and 1346.
C. The Purpose of the Conspiracy
12. The purpose of the conspiracy was for the defendants to use Maczka’s
official position as the mayor of the City of Richardson to benefit and enrich themselves
through bribery.
D. Manner and Means of the Conspiracy
It was part of the manner and means of the conspiracy and the scheme that:
13. At the time Jordan and his partners purchased the Palisades Property, the
Palisades Property was zoned for local retail and office use and for 300 condominiums; it
was not zoned for apartments. Over time, Jordan envisioned transforming the Palisades
Property into a mixed-use development that included, among other things, single-family
units ( houses ) and apartments (collectively referred to as the “Palisades Project”).
According to Jordan’s representative, LG, the Palisades Project would not work without
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the apartments  because of what apartments contribute  to the development. In Fall 2012
and Spring 2013, Jorda  began holding collaborative planning sessions involving local
Richardson stakeholders (e.g., homeowners  associations, City officials, and others), at
which Jordan and LG presented Jordan s plans for the Palisades Project.
14. Before being elected mayor of the City of Richardson, Maczka served on
the Richardson City Council. On November 27, 2012, Maczka announced that she
intended to run for mayor of the City in 2013. During the mayoral campaign in Spring
2013, Maczka publicly stated that there should be no more apartments built in
Richardson near Richardson neighborhoods. Maczka, her then-husband MM, and her
children in fact lived in the Canyon Creek neighborhood immediately next to the
Palisades Property. In one of her campaign advertisements, Maczka stated that “[w]hen
it comes to apartments, you know that Laura has always said we do not need more
apartments near our neighborhoods. Period.  Maczka was elected mayor of the City of
Richardson by a majority vote on May 11, 2013, and began her term on May 20, 2013.
15. In mid-to-late November 2013, shortly before the first vote of the
Richardson City Council on Jordan’s proposed zoning changes for the Palisades
Property, Jordan and Maczka secretly communicated and coordinated with each other
concerning the Palisades Project through, among other means, email communications.
These email exchanges caused wire communications to be made in interstate commerce.
16. On December 9, 2013, the Richardson City Council held a public hearing
before voting on Jordan’s requested zoning changes for the Palisades Property. Many
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citizens of Richardson appeared for the hearing; the overwhelming number of citizens
who spoke at the hearing were adamantly opposed to the proposed increase in apartment
units allowed by the proposed zoning change. Despite this, and despite Maczka s public
campaign pledge to oppose the construction of any new apartments near Richardson
neighborhoods, Maczka spoke and voted in favor of Jordan s zoning changes. At two
more Richardson City Council meetings on January 27 and June 9, 2014, Maczka again
spoke and voted in favor of additional zoning changes requested by Jordan that allowed
for the construction of a total of 1,090 new apartment units on the Palisades Property.
And on September 22, 2014, Maczka voted to authorize the City Manager of the City of
Richardson to negotiate with Jordan and his business partners on a deal that would
obligate the City of Richardson to reimburse Jordan and his partners for various
construction and infrastructure expenses associated with the Palisades Project up to
$47,000,000.
17. In exchange for Maczka’s favorable support and votes regarding the
Palisades Property, Jordan offered and gave to Maczka, and Maczka accepted:
monetary payments, which caused interstate wire communications, payments for
renovations of Maczka’s residence, luxury hotel stays, flight upgrades, meals, lucrative
employment with one of Jordan’s companies that involved the Palisades Property,
intimate sexual contact, and other personal benefits and things of value.
18. Maczka concealed things of value she accepted from Jordan by knowingly
and willfully omitting them from a Local Government Officer Conflicts Disclosure
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Statement ( Conflicts Form ') she was statutorily required to complete under Chapter 176
of the Local Government Code. Maczka failed repeatedly to file the mandatory
Conflicts Form in connection with the things of value Maczka accepted from Jordan.
Maczka also made false and misleading statements to others, including Richardson City
Council members and the Internal Revenue Service (“IRS ), an agency of the United
States Treasury Department, about the things of value she accepted from Jorda , all
designed to conceal the true nature of their corrupt relationship.
19. Jordan concealed things of value he offered and gave to Maczka by
knowingly and willfully causing them to be omitted from Jordan s sworn response to
interrogatories in a Denton County District Court Filing. Jordan also caused the
Contractor to generate a fraudulent invoice concealing Jordan’s payments for Maczka’s
home renovations. Additionally, Jordan made false and misleading statements to others,
including the IRS, about the things of value he offered and gave to Maczka, all designed
to conceal the true nature of their corrupt relationship.
E. Representative Acts of the Conspiracy and the Scheme a d Artifice
20. On or about the following dates in furtherance of the conspiracy, in the
Eastern District of Texas and elsewhere, the defendants caused the following acts to be
committed:
a. During her campaign for election to the office of the mayor of the
City of Richardson, Maczka’s public position was that she was opposed to zoning that
permitted construction of apartments next to neighborhoods. Specifically, Maczka
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authorized and caused to be distributed the following statements in campaign
advertisements:
When it comes to apartments, you know that Laura has always said we do not need more apartments near our neighborhoods. Period, (emphasis in original).
For the record, Lau a has never supported building apartments in or adjacent to our neighborhoods... .Laura is one of our most pro¬ neighborhood councilmembers.. . .She stands with - and for - our neighborhoods.
b. On or about November 5, 2013, Jordan caused a presentation to be
made to the City of Richardson Plan Commission that requested zoning changes for the
Palisades Property. Jordan s zoning request included a decrease in the existing
permissible number of condominiums from 300 to 250, and an increase in the permissible
number of apartments adjacent to the Canyon Creek and Prairie Creek neighborhoods
from 0 to 750.
c. On or about November 11, 2013, Maczka forwarded a constituent s
email to Jordan that contained questions concerning the Palisades Property. On or about
November 14, 2013, Jordan responded to Maczka at approximately 4:31 am with the
following message:
See my answer below in RED. Happens to be my favorite color.. .Don’t forward this to anyone. Just put it in your words....
On or about November 14, 2013, Maczka replied to Jordan’s email with the following message, in part:
Ok....Truly LOL on that one! You’re fairly clever at 4:31 am. I’ll read these responses and will obviously put in my own words. Since we’ve
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already discussed the fact that I have some interesting vocabulary words and it s fairly obvious when other people are writing for me....
d. On or about November 19, 2013, Jordan caused his zoning request
for the Palisades Property to be modified to request zoning that allowed for the
construction of 600 apartments adjacent to the Canyon Creek and Prairie Creek
neighborhoods.
e. On or about November 21, 2013, Maczka sent an email to Jor an
in connection to Jordan s proposed zoning changes in which she stated,  FTR [for the
record], good thing I had such a fun afternoon yesterday. Because last night the prairie
creek mob hit me hard! You were probably enjoying barbecue and chillaxing. I was
taking bullets for you! © . The  prairie creek mob  referred to residents of the Prairie
Creek neighborhood in the City of Richardson that were vocally opposed to the zoning
changes requested by Jordan.
f. On or about December 9, 2013, Maczka, contrary to her campaign
position and over the objection of 126 individuals present at the Richardson City Council
meeting who expressed their opposition, voted in favor of the zoning change that allowed
for the construction of 600 apartments on the Palisades Property adjacent to the Canyon
Creek and Prairie Creek neighborhoods. Only nine individuals present at the meeting
were in favor of the proposed zoning change and expressed their support.
g. On or about January 6, 2014, Jorda  paid for  aczka to stay with
him at the Holiday Inn Express in Plano, Texas.
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h. Between on or about January 14, 2014, to on or about January 16,
2014, Jor an paid for Maczka to stay with him and ski at the Deer Valley Resort at Park
City, Utah, in the approximate amount of $7,206.66.
i. On or about January 27, 2014, at a Richardson City Council
meeting, Maczka voted in favor of the amended zoning change for the Palisades Property
that maintained the permissible number of apartments adjacent to the Canyon Creek and
Prairie Creek neighborhoods at 600, and allowed for additional changes including a
landscape buffer, four acre park, driveways, a ring road, and the construction of single
family homes. Maczka did not disclose to the Richardson City Council or the public
during or prior to the meeting that Jorda  had offered and given to her, and she had
accepted, things of value from Jordan.
j. On or about April 16, 2014, Jordan paid for Maczka to stay with
him at the Corde Valle Resort at San Marten, California, in the amount of $996.82.
k. On or about April 17, 2014, Jordan paid for Maczka to stay with
him at The Ritz-Carlton at Marina del Ray, California, in the amount of $629.49.
l. On or about April 18, 2014, Jordan paid for Maczka s upgrade to
first class on American Airlines Flight 2410 from Los Angeles International Airport to
Dallas-Fort Worth International Airport in the amount of $75.00
m. On or about May 20, 2014, Jordan, at a Richardson City Plan
Commission meeting, caused a modification request to be submitted to the commission
regarding the Palisades Property zoning that included an increase in the number of
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permissible apartments adjacent to the Canyon Creek and Prairie Creek neighborhoods
f om 600 to 1400.
n. On or about June 3, 2014, at a Richardson City Plan Commission
meeting, the proposed number of permissible apartments fo  the Palisades Property
zoning changes was reduced to 1200.
o. On or about June 9, 2014, Jordan and Maczka, at a Richardson City
Council meeting, agreed to reduce the number of permissible apartments for the proposed
Palisades Property zoning changes from 1200 to 1090.
p. On or about June 9, 2014, Maczka, contrary to her campaign
position and over the objection of 651 individuals present at the meeting who expressed
their opposition, voted at a Richardson City Council meeting to approve the Palisades
Property zoning change that allowed for the construction of 1090 new apartments on the
Palisades Property adjacent to the Canyon Creek and Prairie Creek neighborhoods. Only
one individual was present at the meeting who was in favor of the proposed zoning
change. Maczka did not disclose to the Richardson City Council or the public during or
prior to the meeting that Jordan had offered and given to her, and she had accepted,
things of value from Jordan.
q. Between on o  about June 25, 2014, to on or about June 27, 2014,
Jordan paid for Maczka to stay with him at The Ritz-Carlton at Laguna Niguel,
California, in the amount of $2,217.75.
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r. Between on or about August 13, 2014, to on or about August 15,
2014, Jordan paid for Maczka to stay with him at the Montage at Laguna Beach,
California, in the amount of $2,511.13.
s. On or about September 8, 2014, at a Wells Fargo bank branch
located at 1500 Custer Road, Plano, Texas, in the Eastern District of Texas, Maczka
opened Wells Fargo account 1 in her name and designated herself as the sole signatory.
Maczka caused an interstate wire communication to be made when she opened the
account.
t. On or about September 9, 2014, at approximately 1:19 pm, Jordan
made a $1,000 ATM cash withdrawal from his Wells Fargo bank account at 1500 Custer
Road in Plano, Texas, located in the Eastern District of Texas.
u. On or about September 9, 2014, at approximately 2:23 pm, Maczka
made a $300 ATM cash deposit into her Wells Fargo account 1 at 1421 North Central
Expressway in Plano, Texas, located in the Eastern District of Texas.
v. On or about September 15, 2014, Maczka made a $1,000 ATM cash
deposit into her Wells Fargo account 1 at Santa Rosa, Florida.
w. On or about September 16, 2014, Jordan made an $800 ATM cash
withdrawal from his Wells Fargo account at 18190 North Dallas Tollway in Dallas,
Texas, located in the Eastern District of Texas.
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x. Between on or about September 16, 2014, to on or about September
18, 2014, Jordan paid for Maczka to stay with him at The Pearl at Rosemary Beach,
Florida, in the amount of $1,393.52.
y. On or about September 22, 2014, Maczka voted at a Richardson
City Council meeting to authorize the City Manager for the City of Richardson to
negotiate and execute Jor an s DEDA request for the City to reimburse JP-KBS
Richardson Holdings LLC up to $47,000,000 for construction and infrastructure expenses
related to the Palisades Property, and to provide a 25-year, 50% tax rebate for
infrastructure costs. Maczka did not disclose to the Richardson City Council or the
public during or prior to the meeting that Jordan had offered and given to her, and she
had accepted, things of value from Jordan.
z. On or about September 26, 2014, Jordan made two cash
withdrawals in the respective amounts of $800 and $3,000 from his Wells Fargo account
at 18190 Dallas Tollway in Dallas, Texas, located in the Eastern District of Texas.
aa. On or about September 29, 2014, Maczka made an $800 ATM cash
deposit to her Wells Fargo account 1 at 1421 North Central Expressway in Plano, Texas,
located in the Eastern District of Texas.
bb. On or about October 8, 2014, at a Wells Fargo bank branch located
at 1500 Custer Road, Plano, Texas, in the Eastern District of Texas, Maczka opened
Wells Fargo account 2 in her name and designated herself as the sole signatory. Maczka
caused an interstate wire communication to be made when she opened the account.
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cc. On or about October 17, 2014, at approximately 3:49 pm, Jordan
made an $800 ATM cash withdrawal from his Wells Fargo account at 5936 West Park
Boulevard in Plano, Texas, located in the Eastern District of Texas.
dd. On or about October 17, 2014, at approximately 4:00 pm, Maczka
made a $200 ATM cash deposit to her Wells Fargo account 2 at 212 Coit Road in Plano,
Texas, located in the Eastern District of Texas, which was approximately 5 miles from
5936 West Pa k Boulevard in Plano, Texas, where Jordan had withdrawn $800
approximately 11 minutes earlier.
ee. On or about October 24, 2014, at approximately 1:13 pm, Jordan
made a $3,500 cash withd awal from his Wells Fargo account at 1421 North Central
Expressway in Plano, Texas, located in the Eastern District of Texas.
ff. On or about Octobe  24, 2014, at approximately 1:14 pm, Maczka
made a $1,000 ATM cash deposit to her Wells Fargo account 2 at 1421 North Central
Expressway in Plano, Texas, located in the Eastern District of Texas, which was the same
location Jordan had withd awn $3,500 approximately one i inute earlier.
gg. On or about October 24, 2014, at approximately 2:48 pm, Maczka
made a $2,800 ATM cash deposit to her Wells Fargo account 2 at 1421 North Central
Expressway in Plano, Texas, located in the Eastern District of Texas.
hh. On or about October 31, 2014, Maczka made a $ 1,409 ATM cash
deposit to her Wells Fa go account 2 at 212 Coit Road in Plano, Texas, located in the
Eastern District of Texas.
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ii. Between on or abo t October 31, 2014, through on or about
November 30, 2014, Jordan caused the Contractor to perform renovations at Maczka s
residence, including new hardwood floors, staircase, carpeting, painting, and pool repair
and maintenance.
jj. On or about November 5, 2014, Jordan made a $7,000 cash
withdrawal from his Wells Fargo account at 1421 North Central Expressway in Plano,
Texas, located in the Eastern District of Texas.
kk. On or about November 7, 2014, Maczka made a $3,900 ATM cash
deposit to her Wells Fargo account 2 at 212 Coit Road in Plano, Texas, located in the
Eastern District of Texas.
11. On or about November 17, 2014, Jordan made a $5,000 cash
withdrawal from his Wells Fargo account at 1421 North Central Expressway in Plano,
Texas, located in the Eastern District of Texas.
mm. On or about November 20, 2014, Maczka made two ATM cash
deposits in the amounts of $1,840 and $3,000, both to her Wells Fargo account 2 at 3411
Custer Parkway in Richardson, Texas, located in the Eastern District of Texas.
nn. On or about November 26, 2014, at approximately 2:11 pm, Jordan
made an $800 ATM cash withdrawal from his Wells Fargo account at 5936 West Park
Boulevard in Plano, Texas, located in the Eastern District of Texas.
oo. On or about November 26, 2014, at approximately 2:30 pm, Maczka
made a $450 ATM cash deposit into her Wells Fargo account 2 at 212 Coit Road in
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Plano, Texas, located in the Eastern District of Texas, which was approximately 5 miles
from 5936 West Park Boulevard in Plano, Texas, where Jorda  had withdrawn $800
approximately 19 minutes earlier.
pp. Between on or about December 12, 2014, through on or about
December 13, 2014, Jordan gave Maczka a check in the amount of $40,000 that she
deposited in her Wells Fargo account 2 at 1421 North Central Expressway in Plano,
Texas, in the Eastern District of Texas.
qq. On or about December 23, 2014, Jordan knowingly caused the
Contractor to create a fraudulent invoice, number 131-132, that falsely reflected that the
Contractor had performed work, valued at $24,030.02, at one of Jordan s commercial
properties in Irving, Texas, when in fact the Contractor had renovated Maczka’s
residence.
rr. On or about January 4, 2015, Jordan made an $800 ATM cash
withdrawal from his Wells Fargo account at 5936 West Park Boulevard in Plano, Texas,
located in the Eastern District of Texas.
ss. On or about January 5, 2015, at approximately 1:32 pm, Jo dan
made an $800 ATM cash withdrawal from his Wells Fargo account at 212 Coit Road in
Plano, Texas, located in the Eastern District of Texas.
tt. On or about January 5, 2015, at approximately 4:33 pm, Maczka
made a $1,250 ATM cash deposit into her Wells Fargo account 2 at 212 Coit Road in
Plano, Texas, located in the Eastern District of Texas.
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uu. On or about January 11, 2015, Maczka falsely represented herself as
JJ, the then-Human Resources manager at Sooner National Property Management, LP, to
an employee at a furniture store in Dallas, Texas. Maczka selected approximately
$74,000 worth of furniture for Jor an to later purchase. On invoices dated between on
or about January 11, 2015, and on or about March 29, 2015, Maczka caused JJ s name to
be referenced as the individual who selected and ordered the furniture with a
corresponding cellular telephone number that in fact belonged to Maczka, not JJ.
vv. On or about January 14, 2015, at approximately 1:24 pm, Maczka
made a $300 ATM cash deposit into her Wells Fargo account 2 at 3411 Custer Parkway
in Richardson, Texas, located in the Eastern District of Texas.
ww. On or about January 14, 2015, at approximately 6:58 pm, Jor an
made an $800 ATM cash withdrawal from his Wells Fargo account at 995 West Bethany
in Allen, Texas, located in the Eastern District of Texas.
xx. On or about February 9, 2015, Jordan issued a check drawn on a
Sooner National Property Management, LP checking account to the Company in the
amount of $24,030.02 for payment for renovations completed at Maczka s home.
yy. On or about February 23, 2015, Jordan made an $800 ATM cash
withdrawal from his Wells Fargo account at 1421 North Central Expressway in Plano,
Texas, located in the Eastern District of Texas.
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zz. On or abo t February 24, 2015, Maczka made a $240 ATM cash
deposit into her Wells Fargo account 2 at 3411 Custer Parkway in Richardson, Texas,
located in the Eastern District of Texas.
aaa. On or about March 2, 2015, Jorda  offered Maczka employment at
Jordan s business, Sooner National Property Management, LP, as a leasing agent.
Jordan chose to replace the departing Employee - a leasing agent who was licensed by
the State of Texas Real Estate Commission and whose annual salary was approximately
$70,000 - with Maczka who was not licensed and had no experience or ed cation
relevant to leasing commercial property. Jordan offered Maczka an annual salary of
$150,000, a signing bonus of $15,000, and discretionary and year-end bonuses.
bbb. On or about March 13, 2015, Jordan gave Maczka a check in the
amount of $9,617.20, which was the post-tax amount of the offered and accepted $15,000
signing bonus.
ccc. On or about March 16, 2015, Maczka, in an attempt to conceal the
true nature of her corrupt relationship with Jordan, caused MM, her ex-husband, to file a
fraudulent and incomplete 2014 U.S. Individual Income Tax Return, Form 1040 (the
2014 Tax Return ). Maczka failed to identify and include any of the 2014 monetary
payments Jordan provided to her in the 2014  fax Return.
ddd. On or about March 19, 2015, Maczka, in an attempt to conceal the
things of value offered by Jordan and accepted by her, knowingly submitted a fraudulent
Conflicts Disclosure Statement to the City of Richardson that falsely omitted things of
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value offered by Jordan and accepted by Maczka. Maczka s fraudulent submission
reflected she had accepted no gifts with an aggregate value of $250 or more offered by
Jordan.
eee. On or about April 8, 2015, the City of Richardson retained an
attorney, GS, to conduct an independent investigation into alleged ethical violations
concerning the events surrounding the approval of the rezoning for the Palisades
Property.
fff. On or about April 9, 2015, GS caused a letter to be sent to JS,
Maczka s then-attorney, in which GS requested to know when Maczka  entered into a
financial or other business relationship with Jordan/JP Realty.  The letter also asked “If
[Maczka] received money or anything of value from such developer [Jordan], we would
like to have it described together with the date it was paid or provided.”
ggg. On or about April 17, 2015, Maczka, in an attempt to conceal the
true nature of the corrupt relationship between Jorda  and Maczka and the things of
value offered by Jordan and accepted by Maczka, caused he  then-attorney, JS, to
submit a fraudulent letter to GS that falsely stated:
At no time [between November 5, 2013 and June 9, 2014] was there any suggestion of, offer of, acceptance, or any implication that any form of personal financial benefit would be provided to the Mayor [Maczka], nor would it have been accepted had it been made.
Maczka’s letter submitted to GS through her then-attorney, JS, neither identified nor
disclosed any of the things of value offered by Jordan that were accepted by Maczka.
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hhh. On or about April 20, 2015, Maczka, in an attempt to conceal the
true nature of the corrupt relationship between Jordan and Maczka and the things of
value offered by Jordan and accepted by Maczka, sent an email to a journalist in which
she stated, among other things, the following to the below question:
Question: Did you have an inappropriate relationship with JP Partners resulting in a conflict of interest?
Maczka: No
iii. On or about April 28, 2015, GS issued a report of his investigation in
which he stated:
We spoke by telephone with Jordan at J.P. Realty Partners, Ltd., who confirmed that neither he, nor his company had a financial or other business relationship with the Mayor [Maczka] prior to October 2014. He [Jordan] also stated that the Mayor did not receive any financial or other benefit from him or his company prior to her employment in 2015. Mr. Jordan also recalled making a $500 political campaign contribution to the Mayor for her previous election and made an equal donation to her opponent.
jjj. On or about April 28, 2015, Maczka, at a Richardson City Council
Special Called meeting,  addressed the conflict of interest ethics investigation  regarding
the Palisades and Jordan. She stated the following about her relationship with Jordan.
Much has been discussed about my relationship with the developer, Jordan.. .1 acknowledge that I have a personal relationship with Mark. We became friends through the zoning process and that friendship has continued. As he has done for other friends, when I needed a job and he had an opening, he offered me the opportunity....
In an attempt to mislead the citizens of the City of Richardson and conceal the true nature
of her corrupt relationship with Jordan and the things of value offered by Jordan that
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were accepted by her, Maczka knowingly and willfully failed to disclose to the
Richardson City Council or to the public the true nature of the corrupt relationship,
including the things of value she had accepted from Jordan.
kkk. On or about April 29, 2015, Jordan executed the DEDA on behalf
of JP-KBS Richardson Holdings, EEC as its managing member.
111. On or about May 7, 2015, the City of Richardson city manager
executed the DEDA on behalf of the City of Richardson.
mmm. On or about July 7, 2015, Jordan, in an attempt to conceal the true
nature of the corrupt relationship between Jordan and Maczka, knowingly executed
under oath the  Answers to Respondent s Written Interrogatories to Petitioner  that
falsely reflected he had neither offered nor gave Maczka any “gifts, transfers of funds, or
money in excess of $250 since January 1, 2010,  when in fact Jordan knew that he had
given and offered Maczka such things of value since January 1, 2010. Additionally with
the intent to conceal the true nature of the corrupt relationship, Jordan knowingly under
oath caused the “Answers to Respondent’s Written Interrogatories to Petitioner  to
falsely reflect that Jordan did not engage in “intimate sexual contact  with Maczka until
“July 2014,  when in fact Jordan knew that he had engaged in intimate sexual contact
with Maczka as early as in or about January 2014.
nnn. On or about July 7, 2015, Jordan caused the fraudulent “Answers to
Respondent’s Written Interrogatories to Petitioner  to be filed in Denton County District
Court, located in the Eastern District of Texas.
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ooo. On or about July 20, 2016, Jorda , on behalf of Sooner National
Property Management, LP and in an attempt to conceal the true nature of the corrupt
relationship between Jordan and Maczka, caused GK, Jordan s accountant, to file a
fraudulent 2015 U.S. Return of Partnership Income, Form 1065 (the  2015 Tax Return ).
Jordan caused GK to depreciate and claim the $24,030.02 expense to renovate
Maczka’s residence as a business deduction in the approximate amount of $14,000
concerning the Company s fraudulent invoice, number 131-132, in the 2015 Tax Return.
In violation of 18 U.S.C. § 1349.
Co nts Two thro gh Four
Violation: 18 U.S.C. §§ 1343, 1346 (Honest Services Wire Fraud)
A. Introd ction
1. The grand jury re-alleges the allegations contained in Paragraphs 1 through
10 and Paragraphs 13 through 20 of Count One of this Indictment and further alleges
that:
B. The Scheme and Artifice to Defraud
2. Maczka and Jordan devised a scheme and artifice to deprive the citizens
of the City of Richardson, through fraud, of their right to the honest services of the mayor
of the City of Richardson free from corrupt influence, and, in execution of the scheme
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and artifice, caused writings, signs, and signals to be transmitted by means of wire
communications in interstate commerce.
C. The Purpose of the Scheme and Artifice
3. The purpose of the scheme and artifice was for the defendants to use
Maczka s official position as the mayor of the City of Richardson to benefit and enrich
themselves through bribery.
D. The Execution of the Scheme and Artifice
4. On or about the following dates, in the Eastern of District of Texas and
elsewhere, the following defendants, for the purpose of executing the scheme and artifice,
caused the following wire transmissions from the Eastern District of Texas to the State of
Minnesota, regarding the following bank action and transactions in the following
amounts, to be made in interstate commerce:
Count Defendant Date Bank Action 2 Maczka September 8, 2014 Opened Wells Fargo account 1 ending in 1020
Count Defendant Date Bank Transaction Type Amount 3 Jordan September 9, 2014 ATM Cash Withdrawal $1,000
4 Maczka September 9, 2014 ATM Cash Deposit $300
All in violation of 18 U.S.C. §§ 1343 and 1346.
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Count Five
Violation: 18 U.S.C. § 371 (Conspiracy to Commit Bribery Concerning A Program Receiving Federal Funds)
A. Introductio
1. The grand jury re-alleges the allegations contained in Paragraphs 1 through
10 and Paragraphs 13 through 19 of Count One of this Indictment and further alleges the
following.
2. At all times material to this Indict ent, the City of Richardson was a local
government that received federal assistance in excess of $10,000 during each of calendar
years 2013, 2014, and 2015.
B. Conspiracy
3. Between in or around May 2013, through on or about July 31, 2015, in the
Eastern District of Texas and elsewhere, Maczka conspired, combined and agreed with
Jordan to:
(a) corruptly accept and agree to accept a thing of value from Jordan, intending to
be influenced and rewarded by Jordan in connection with a business,
transaction, and series of transactions with the City of Richardson involving a
thing of value of $5,000 or more (a violation of 18 U.S.C. § 666(a)(1)(B)); and
(b) corruptly give, offer, and agree to give a thing of value to Maczka, with the
intent to influence and reward Maczka, an agent of the City of Richardson, in
connection with a business, transaction, and series of transactions with the City
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of Richardson involving a thing of val e of $5,000 or more (a violation of 18
U.S.C. § 666(a)(2)).
C. Overt Acts of the Conspiracy
4. The Grand Jury re-alleges the facts contained in Paragraph 20 of Count One
of this Indictment.
In violation of 18 U.S.C. § 371.
Count Six
Violation: 18 U.S.C. § 666(a)(1)(B) (Bribery Concerning Program Receiving Federal Funds)
1. The grand jury re-alleges the allegations contained in Paragraphs 1 through
10 and Paragraphs 13 through 20 of Count One of this Indictment, Parag aph 2 of Count
Five of this Indictment, and further alleges the following.
2. Between in or around May 2013, through on or about July 31, 2015, in the
Eastern District of Texas and elsewhere, Maczka, defendant, corruptly accepted a thing
of value from Jordan, intending to be influenced and rewarded by Jordan in connection
with a business, transaction, and series of transactions with the City of Richardson
involving a thing of value of $5,000 or more.
In violation of 18 U.S.C. § 666(a)(1)(B).
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Count Seven
Violation: 18 U.S.C. § 666(a)(2) (Bribery Concerning Program Receiving Federal Funds)
1. The grand jury re-alleges the allegations contained in Paragraphs 1 through
10 and Paragraphs 13 through 20 of Count One of this Indictment, Paragraph 2 of Count
Five of this Indictment, and further alleges the following.
2. Between in or around May 2013, through on or about July 31, 2015, in the
Eastern District of Texas and elsewhere, Jordan, defendant, corruptly gave and offered a
thing of value to Maczka, with the intent to influence and reward Maczka, an agent of the
City of Richardson, in connection with a business, transaction, and series of transactions
with the City of Richardson involving a thing of value of $5,000 or more.
In violation of 18 U.S.C. § 666(a)(2).
NOTICE OF INTENT TO SEEK CRIMINAL FORFEITURE
Pursuant to 18 U.S.C. S 98Ua m(Q and 28 U.S.C. $ 2461
As the result of committing the offenses alleged in this Indictment, the defendants
shall forfeit to the United States:
any property, real or personal, which constitutes or is derived from proceeds
traceable to a violation of any offense constituting  specified unlawful activity  (as
defined in 18 U.S.C. § 1956(c)(7)), or a conspiracy to commit such offense, including,
but not limited to, the following:
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Cash Procee s
A money judgment in United States currency and all interest and proceeds
traceable thereto, in that such sum in aggregate is property constituting, or derived from,
proceeds obtained directly or indirectly, as the result of the offenses alleged in this
Indictment.
Substitute Assets
If any of the property described above as being subject to forfeiture, as a result of
any act or omission of the defendants
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with a third person;
(c) has been placed beyond the jurisdiction of the court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be subdivided without difficulty;
it is the intent of the United States, pursuant to 21 U.S.C. § 853(p), to seek forfeiture of
any other property of the defendants up to the value of the above forfeitable property,
including but not limited to all property, both real and personal owned by the defendants.
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By virtue of the commission of the offenses alleged in this Indictment, any and all
interest the defendants have in the above-described property is vested in and forfeited to
the United States.
A TRUE BILL
GRAND JURY FOREPERSON
JOSEPH D. BROWN UNITED STATES ATTORNEY
CHRISTOPHER A. EASON Date Assistant United States Attorney Oklahoma Bar No. 20197
G.R. JACKSON Assistant United States Attorney Texas Bar No. 00784874
BRADLEY VISOSKY Assistant United States Attorney Texas Bar No. 24034727
101 East Park Boulevard, Suite 500 Plano, Texas 75074 Telephone: (972) 509-1201
ATTORNEYS FOR THE UNITED STATES
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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION
UNITED STATES OF AMERICA § § §V. No. 4:18CR § Judge LAURA JORDAN (1) § a/k/a Laura Maczka § MARK JORDAN (2) §
NOTICE OF PENALTY
Count One
Violation:
Penalty:
Special Assessment:
Violation:
18U.S.C. § 1349 (Conspiracy to Commit Honest Services Wire Fraud)
A fine of not more than $250,000, or twice the gross pecuniary gain or loss, and/or imprisonment for not more than 20 years, and a term of supervised release for not more than 5 years.
$100.00
Co n s Two thro gh Four
18U.S.C. §§ 1343, 1346 (Honest Services Wire Fraud)
Penalty: For each count: A fine of not more than $250,000, or twice the gross pecuniary gain or loss, and/or imprisonment for not more than 20 years, and a term of supervised release for not more than 5 years.
Special Assessment: For each count: $100.00
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Count Five
Violation: 18U.S.C. §371 (Conspiracy)
Penalty: A fine of not more than $250,000, or twice the gross pecuniary gain or loss, and/or imprisonment for not more than 5 years, and a term of supervised release for not more than 3 years.
Special Assessment: $100.00
Count Six
Violation: 18 U.S.C. § 666(a)(1)(B) (Bribery Concerning Program Receiving Federal Funds)
Penalty: A fine of not more than $250,000, or twice the gross pecuniary gain or loss, and/or imprisonment for not more than 10 years, and a term of supervised release for not more than 3 years.
Snecial Assessment: $100.00
Count Seve
Violation: 18 U.S.C. § 666(a)(2) (Bribery Concerning Program Receiving Federal Funds)
Penalty: A fine of not more than $250,000, or twice the gross pecuniary gain or loss, and/or imprisonment for not more than 10 years, and a term of supervised release for not more than 3 years.
Special Assessment: $100.00
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