UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MISSOURI

EASTERN DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.                                        No. 4:05CR00283HEA

CASSANDRA WILLIAMS,

Defendant.

INDICTMENT

COUNT ONE

The Grand Jury charges that:

On or about October 28, 2004, in the Eastern District of Missouri,

CASSANDRA WILLIAMS,

the defendant herein, in a matter within the jurisdiction of the Department of Labor, Office of Labor Management Standards, a department of the United States, knowingly and willfully made materially false, fictitious and fraudulent statements and representations, to wit: defendant CASSANDRA WILLIAMS advised an Investigator for the Department of Labor, Office of Labor Management Standards that documents she submitted that day, including e-mail messages and a letter from the Salvation Army were true and correct, when in truth and fact, as the defendant CASSANDRA WILLIAMS then knew, she had altered these documents in an attempt to make it appear that she had made a contribution to the Salvation Army.

In violation of Title 18, United States Code, Section l001(a)(2)

COUNT TWO

The Grand Jury further charges that:

On or about October 28, 2004, in the Eastern District of Missouri,

CASSANDRA WILLIAMS,

the defendant herein, did corruptly influence, obstruct and impede, and endeavor to influence, obstruct and impede the due and proper administration of the law under which a pending proceeding, to wit: an investigation by the United States Department of Labor, Office of Labor Management Standards into whether payments made by the American Federation of Government Employees, Local 905, were lawfully made was being had before the United States Department of Labor, Office of Labor Management Standards, by presenting to investigators of the United States Department of Labor, Office of Labor Management Standards documents which the defendant had altered in an attempt to justify the payments being investigated.

In violation of Title 18, United States Code, Section 1505.

A TRUE BILL.

                                    ______________________

FOREPERSON

JAMES G. MARTIN

United States Attorney

__________________________

DAVID M. ROSEN #23537

Assistant United States Attorney