UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff, CRIMINAL NO. 03-80660
v. HONORABLE NANCY G. EDMUNDS
VIOLATION: 18 U.S.C. §§ 1343
D-1 LARRY E. BENNETT, 1346
OFFENSE: Wire Fraud/Theft of
Honest Services
FILED: JULY 10, 2003
Defendant.
/
INFORMATION
The United States of America, acting through its attorneys, charges:
I.
DESCRIPTION OF THE OFFENSE
1. Larry E. Bennett is made a defendant on the charge stated below.
2. Defendant, at all times relevant, lived in Plymouth, Michigan, which is
located within the Eastern District of Michigan, and was president of
Premiere Video, Inc., a company located in Livonia, Michigan that duplicated
and distributed videotapes.
3. Defendant and an executive ("executive") of an audio-visual company located
in Troy, Michigan (“company”), which buys licensing rights from television
and movie programers, then packages these properties for retail sale as
videotapes and DVDs, willfully devised a scheme to commit wire fraud by
depriving the company of the honest services of one of its executives and
permitted the executive to obtain money by means of false or fraudulent
pretenses in violation of Title 18 U.S.C. §§ 1343 and 1346.
4. The executive and the defendant willfully entered into a scheme to defraud in
which the defendant agreed in a series of meetings and telephone calls to pay
the executive monies in exchange for his continued support in contract
negotiations, and to prevent Premiere’s business with the company from
being jeopardized. In so doing, the defendant willfully entered into a scheme
to defraud. The scheme to defraud deprived the company of the honest
services of its executive and permitted the executive to obtain monies by
means of false or fraudulent pretenses.
II.
USE OF WIRES
5. As part of the scheme, and for the purpose of executing the scheme to
defraud, on or about January 8, 2001, defendant willfully directed the
transmission over interstate wires of a $29,667 payment for the benefit of the
executive. The defendant caused the wire transfer to cross from the Eastern
District of Michigan, where the defendant was located, to Pennsylvania and
ultimately to Arkansas for the purpose of furthering or executing the scheme
to defraud, all in violation of Title 18, United States Code, Sections 1343,
1346.
III.
JURISDICTION AND VENUE
6. The scheme charged in this Information was devised and carried out, in part,
in the Eastern District of Michigan, within the five years preceding the filing
of this Information.
IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1343 AND
1346.
“/s/” “/s/”
R. HEWITT PATE SCOTT M. WATSON
Acting Assistant Attorney General Chief, Cleveland Field Office
“/s/” “/s/”
JAMES M. GRIFFIN KEVIN C. CULUM
Deputy Assistant Attorney General [3460--MT]
BRIAN J. STACK
[069796--OH]
“/s/” ANTOINETTE E. THOMAS
SCOTT D. HAMMOND [474696-DC], [MD]
Director of Criminal Enforcement Attorneys
Antitrust Division
Antitrust Division U.S. Department of Justice
U.S. Department of Justice Plaza 9 Building
55 Erieview Plaza, Suite 700
Cleveland, OH 44114-1816
Telephone: (216) 522-4014
Fax: (216) 522-8332
JEFFREY G. COLLINS
United States Attorney
Eastern District of Michigan
“/s/”
ALAN GERSHEL
Criminal Chief, E.D. Michigan
Dated: July 10, 2003