Office of Labor-Management Standards (OLMS)
KEVIN V. RYAN (CASBN 118321)
United States Attorney
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORMA
UNITED STATES OF AMERICA,
CR 03- 40097
VIOLATION: 29 U.S.C. § 501(c)Theft of Labor Organization Money by Employee
The Grand Jury charges:
COUNT ONE (29 U.S.C. § 501(c))
1. At all times relevant to this indictment, Local 250 of the Service Employees International Union, also known as Local 250 of the Health Care Workers Union, was a labor organization engaged in an industry affecting commerce and Adela Tongson was an employee of Local 250.
2. On or about November 29, 1999, in the Northern District of California, and elsewhere, the defendant
did unlawfully and willfully embezzle, steal, abstract, and convert to her own use and the use of others moneys, funds, securities, property and other assets of Local 250, to wit, approximately
$41,528.88, in violation of Title 29, United States Code, Section 501(c).
COUNT TWO (29 U.S.C. § 501(c))
3. Paragraph 1 is incorporated by reference as if set forth in full.
4. On or about November 30, 1999, in the Northern District of California, and elsewhere, the defendant
did unlawfully and willfully embezzle, steal, abstract, convert to her own use and the use of others moneys, funds, securities, property and other assets of Local 250, to wit, approximately $58,471.12, in violation of Title 29, United States Code, Section 501(c).
A TRUE BILL
KEVIN V. RYAN
United States Attorney
CHARLES B. BURCH
Chief, Criminal Division
(Approved as to form:/SIGNED/____________)
AO 257 (Rev. 6/78)
DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION - IN U.S. DISTRICT COURT
BY: [ ] COMPLAINT [ ] INFORMATION [X] INDICTMENT [ ] Superseding
Title 29, United States Code Section 501(c)-- Theft of Labor Organization Money b Employee (2 counts)
[ ] Petty
[ ] Minor
[ ] Misdemeanor
Each count: 5 years imprisonment, $250,000 fine, 3 years supervised release. $100 special assessment, restitution
Name of Complainant Agency or Person (& Title, if any): Labor Dept.
[ ] person is awaiting trial in another Federal or State Court give name of court.
[ ] this person/proceeding is transferred from another district per (circle one) FRCrP 20, 21 or 40. Show District
[ ] this is a prosecution of charges previously dismissed which were dismissed on motion of [ ] U.S. Att’y [ ] Defense _________SHOW DOCKET NO.
[ ] this prosecution relates to a pending case involving this same defendant
[ ] prior proceedings or appearance(s) before U.S. Magistrate regarding this defendant were recorded under _______________MAGISTRATE NO.
Name and Office of Person Furnishing Information on
KEVIN V. RYAN
[X] U.S.Att’y [ ] Other U.S. Agency
Name of Asst. U.S. Att’y ______________
Name of District Court, and/or Judge/Magistrate Location
NORTHERN DISTRICT OF CALIFORNIA
DEFENDANT – U.S
DISTRICT COURT NUMBER: CR 03 - 0097
IS NOT IN CUSTODY
1) [X] Has not been arrested, pending outcome this proceeding.
If not detained give date any prior summons was served on above charges
2) [ ] Is a Fugitive
3) [ ] Is on Bail or Release from (show District) ________________
IS IN CUSTODY
4) [ ] On this charge
5) [ ] On another conviction
6) [ ] Awaiting trial on other charged
If answer to (6) is “Yes”, show name of institution __________________
Has detainer been filed? [ ] Yes [ ] No
If “Yes” give date filed______________________
DATE OF ______________________
Or... if Arresting Agency & Warrant were not
TO U.S. CUSTODY
[ ] This report amends AO 257 previously submitted
ADDITIONAL INFORMATION OR COMMENTS
[ ] SUMMONS [ ] NO PROCESS* [X] WARRANT Bail Amount: No bail.
If Summons, complete following:
[ ] Arraignment [ ] Initial Appearance
* Where defendant previously apprehended on complaint, no new summons or warrant needed, since Magistrate has scheduled arraignment.