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UNITED STATES DISTRICT COURT
Grand Jury Sworn in on April 29, 2005
The Grand Jury charges that:
COUNT ONE (18 U.S.C. § 201(c))
1. At all times relevant to this Indictment, Defendant
was employed as a Vice President of DMJM+Harris, Inc. (formerly Frederick R. Harris, Inc.), a traffic engineering firm. In October 2001, Frederick R. Harris, Inc. changed its name to DMJM+Harris, Inc. The corporate structure remained the same and the company retained the same Federal Indentification number. Frederick R. Harris, Inc. and DMJM+Harris, Inc. are hereinafter referred to collectively as "DMJM."
2. In September 2000, DMJM was awarded an operational support contract from the District of Columbia, Department of Transportation ("DC DOT"), D.C. Formal Agreement No. 014-98, for one year plus the possibility of four option years. The value of the contract was projected to be worth approximately $12.9 million over the life of the contract if the DC DOT exercised all four option years.
3. In his capacity as Vice President of DMJM, Defendant KEITT had primary responsibility over DMJM's work under the operational support contract.
4. During the relevant time period, Person A was employed as a public official, namely the Associate Director in charge of the Traffic Services Administration, a division of the DC DOT. In his capacity as Associate Director, Person A was responsible for the administration and oversight of DMJM's operational support contract. He also had authority to terminate DMJM's performance under that contract and his input determined whether the contract was annually renewed. Moreover, as Associate Director, Person A was responsible for the provision of millions of dollars worth of emergency traffic services for the District of Columbia after the terrorist attacks of September 11, 2001.
5. During the period October 2001 until in or about December 2001, the exact date being unknown to the Grand Jury, in the District of the District of Columbia and elsewhere, Defendant KEITT, otherwise than as provided by law for the proper discharge of official duty, directly or indirectly gave, offered, and promised a thing of value to a public official for or because of an official act performed or to be performed by such public official; that is Defendant KEITT gave Person A $6900 for or because of official acts performed or to be performed by Person A relating to the operational support contract, including his favorable treatment in administering and overseeing the contract, his positive input regarding the annual renewal of the contract, his favorable exercise of discretion not to terminate the contract, and his consideration of DMJM's proposals, suggestions and solicitations for the provision of emergency traffic services after September 11, 2001.
Jurisdiction and Venue
6. The offense charged in this Indictment was carried out in the District of Columbia within the five years preceding the return of this Indictment, excluding the period during which the running of the statute of limitations was suspended pursuant to agreement with the Defendant.
IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 201.
DATED: February 23, 2007