REC Bid District COURT OF THE UNITED STATES FOR THE MIDDLE DISTRICT OF ALABAMA ‘200 SEP 24 P 321 NORTHERN DIVISION DEBRA P. HACKETT. CLIC UNITED ISTRICT ALE } v. ) ) JENNIFER DOUGHERTY POUNCY ) ) The United States charges: COUNTI 1. Between in or about April 2006 until in or about May 2010, the defendant, JENNIFER DOUGHERTY POUNCY, was employed as a registered lobbyist by a lobbying firm located in Montgomery, Alabama, which was headed by Lobbyist 1. 2. Lobbyist 1's largest client was Businessman 1. Businessman 1 owned a controlling. interest in an entertainment development project in Houston County, Alabama, which was an entertainment and resort venve that offered live country music performances, upscale hotel accommodations, and casino-style electronic bingo machines. 3. Businessman 2 has the controlling interest in an upscale hotel that offers entertainment, dog recing, and casino-style electronic bingo in Macon County, Alabama, Businessman 2 also shares an ownership interest in Businessman 1's entertainment and resort venue. 4. — The legislature for the State of Alabama consists of two bodies, the Alabama State ‘Senate and the Alabama House of Representatives, Senators and Representatives are elected to four- year terms, Alabama State Senators and Representatives are agents of the State of Alabama.5. Incalendar years 2009 and 2010, the State of Alabama received benefits in excess of $10,000 pursuant to federal programs providing assistance to the State. 6, 12009, gambling supporters in the State of Alabama formed a coalition to promote the passage of pro-gambling legislation favorable to the interests of businessmen - suchas Businessmen. 1 and 2 - who owned and operated facilities that offered electronic bingo. Although the pro- ‘gambling legistation was drafted, it was not put toa vote by the Alabama legislature during its 2009 session. At the commencement of the Alabama legislature’s 2010 session, various members of the Alabama Senate and House of Representatives introduced legislation that, if enacted, would have promoted the business interests of electronic-bingo facility owners and operators. Among that ‘proposed legislation was Senate Bill 380 7. Businessmen | and 2 sought to influence the passage of Senate Bill 380 by buying the votes of Alabama legislators. Specifically, some time in or around January 2009 until some time in or around April 2010, Businessman 1 employed Lobbyist 1 and his lobbying firm to bribe Alabama legislators with money and other things of value in exchange for votes in favor of the passage of Senate Bill 380. Lobbyist 1 and Businessman 1 acted in concert with Businessman 2 as part of this conspiracy. The defendant acted under the direction of and was supervised by Lobbyist 1 and Businessman 1 as part of these efforts to offer bribes to Alabama legislators in exchange for their ‘votes in favor of Senate Bill 380. Furthermore, the defendant knew that Businessman 2 employed Lobbyist 2. Lobbyist 1 told the defendant that Lobbyist 2 had communicated offers of things of value to legislators in exchange for pro-gambling votes. 8. From on or about February 1, 2009, and continuing through on or about May 1, 2010, in Montgomery County in the Middle District of Alabama and elsewhere, defendantJENNIFER DOUGHERTY POUNCY, did knowingly conspire with others known and unknown to the United States to commit bribery in a program receiving federal funds, in that: 9. the defendant and others corruptly gave, offered, and agreed to give money and other things of value to Alabama State legislators with intent to influence and reward the Alabama State legislators in connection with pro-gambling legislation, which was any business, transaction, and series of transactions of Alabama involving anything of value of $5,000 or more in violation of Title 18, United States Code, Section (666(a)(2); and Alabama State legislators corruptly solicited, demanded, accepted, and agreed to accept money and things of value from defendant and others, intending to be influenced and rewarded in connection with pro-gambling legislation, which was any business, transaction, and series of transactions of Alabama involving anything of value of $5,000 or more, in violation of Title 18, United States Code, Section 666(a)(1)(B). In furtherance of the conspiracy and to achieve its purposes, the defendant and others committed overt acts in the Middle District of Alabama and elsewhere, including the following: a. Between on or about March 1, 2010, and on or about March 31, 2010, the defendant met with Senator 1, an Alabama State Senator, and offered him $2,000,000. b. On or about March 24, 2010, Senator 2, an Alabama State Senator, approached the defendant and asked for a $100,000 campaign contribution from Businessman | and Lobbyist 1. It ‘was clear to the defendant that Senator 2 was requesting the money in exchange for his vote for thepassage of specific pro-gambling legislation, Senate Bill 380, and she conveyed this belief to Lobbyist 1, who then conveyed it to Businessman 1, c. Acting under Lobbyist I's instructions, the defendant told Senator 2 that Lobbyist 1 and Businessman 1 would make the $100,000 contribution, Senator 2 asked the defendant if “they were talking about the same thing,” and she replied, “yes.” The defendant understood that Senator? was being bribed so that he would support Senate Bill 380. d. Some time before the end of 2009 or at the beginning of 2010, Senator 3 called the defendant a Lobbyist 1's lobbying firm. During the call, Senator 3 told the defendant that he wanted ‘a campaign contribution from Lobbyist 1 and Businessman 1. Senator 3 was very direct and demanded either $5,000 or $10,000. During the call, Senator 3 told the defendant that he believed that he deserved the campaign contribution because he had sponsored the pro-gambling legislation in the 2009 legislative session, and that he was no longer “feeling the love.” It was clear to the defendant that Senator 3 was demanding the money to ensure his continued support for pro-gambling legislation. The contributions were made as demanded. ¢. At various times in 2010, Lobbyist I received requests from Senator 3 for money. The defendant considered the demands for money to have been made with the clear intent to convey that he deserved the money as a reward for supporting Senate Bill 380, and that if he did not receive the money, he would no longer support Senate Bill 380. £. Some time between on or about March 15, 2010, and March 30, 2010, Senator 3 called Lobbyist 1 and asked for $25,000 in exchange for Senator 3's support for Senate Bill 380.All in violation of Title 18, United States Code, Section 371. Chief for Litigation Public Integrity Section