Enforcement Actions

IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

INDICTMENT

THE GRAND JURY CHARGES THAT:

COUNT 1

On or about March 28, 2003, in Calhoun County, in the Southern Division of the Western District of Michigan,

BRAD RICHARD HARPER,

in a matter within the jurisdiction of the United States Department of Labor ("DOL"), did knowingly and willfully make and use a false writing and document by presenting to DOL a false Labor Organization Annual Report Form LM-3 ("LM-3"), for Local 1629 of the American Federation of Government Employees, knowing that the LM-3 did not report illegal disbursements of funds to BRAD RICHARD HARPER.

18 U.S.C. § 1001(a)(1)

COUNT 2

On or about March 30, 2004, in Calhoun County, in the Southern Division of the Western District of Michigan,

BRAD RICHARD HARPER,

in a matter within the jurisdiction of the United States Department of Labor ("DOL'), did knowingly and willfully make and use a false writing and document by presenting to DOL a false Labor Organization Annual Report Form LM-3 ("LM-3"), for Local 1629 of the American Federation of Government Employees, knowing that the LM-3 did not report illegal disbursements of funds to BRAD RICHARD HARPER.

18 U.S.C. § 1001(a)(1)

COUNT 3

On or about March 21, 2005, in Calhoun County, in the Southern Division of the Western District of Michigan,

BRAD RICHARD HARPER,

in a matter within the jurisdiction of the United States Department of Labor ("DOV), did knowingly and willfully make and use a false writing and document by presenting to DOL a false Labor Organization Annual Report Form LM-3 ("LM-Y), for Local 1629 of the American Federation of Government Employees, knowing that the LM-3 did not report illegal disbursements of funds to BRAD RICHARD HARPER.

18 U.S.C. § 1001(a)(1)

A TRUE BILL
GRAND JURR FOREPERSON

CHARLES R. GROSS
United States Attorney

JULIE ANN WOODS
Assistant United States Attorney