Indictment — United States v. Jackson (Dkt. 1, filed 2023-11-01)

Summary

An indictment returned by the Special October 2022 Grand Jury in United States v. Lawrence Jackson, Case 1:23-cr-00585, in the U.S. District Court for the Northern District of Illinois, Eastern Division, filed November 1, 2023 as Document #: 1. It charges violations of Title 18, United States Code, Sections 1512(c)(2) and 1623(a). The indictment describes a civil suit, Tri-State Disposal Inc. v. the Village of Riverdale et al., No. 18 CV 2138, over Riverdale's garbage collection contract. It charges that Jackson made false declarations and that on or about February 25, 2021 he falsely testified in a deposition in that suit, including about his wife's role in a business, in an attempt to obstruct an official proceeding.

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Case: 1:23-cr-00585 Document #: 1 Filed: 11/01/23 Page 1 of 11 PagelD #:1

FiLE D

          _       _        UNITED STATES DISTRICT COURT
     NOV - 12023      (NORTHERN DISTRICT OF ILLINOIS

THOMAS G BRUTON                    EASTERN DIVISIO}
CLERK, U.S. DISTRICT COURT                              23-CR-585
      UNITED STATES OF AMERICA                )         JUDGE GETTLEMAN
                                              ) No.     MAGISTRATE JUDGE COLE
                  v.                          )
                                              ) Violations: ‘litle 18, United States
      LAWRENCE JACKSON                        ) Code, Sections 1512(c)(2) and
                                              ) 1623(a)

                                       COUNT ONE

            The SPECIAL OCTOBER 2022 GRAND JURY charges:

            1.    At times material to this indictment:

                               Relevant Entities and Individuals

                  a.    Individual A was the president and director of Company A-1, a

      waste hauling services company based in Markham, Illinois.

                  b.    Individual A and his wife were the operator and manager,

      respectively, of another one of Individual A’s Businesses, Company A-2, a recycling

      and waste transfer business located in Riverdale that sold recycled construction and

      building materials.

                  ¢.    Individual A owned and or controlled several other businesses in

      the Northern District of Illinois (collectively, “Individual A’s Businesses”).

                  d.    Defendant LAWRENCE JACKSON was the president of the

      Village of Riverdale, a municipality in the Northern District of Illinois (“Riverdale”).

                  e.    Beginning no later than in or around September 2017,

      JACKSON’s wife, who was otherwise employed full-time, was also employed and paid

      by one of Individual A’s Businesses.

Case: 1:23-cr-00585 Document #: 1 Filed: 11/01/23 Page 2 of 11 PagelD #:2

f. JACKSON and his’ wife owned Centennial Holdings
(“Centennial”), a trucking company established in or around March 2018.

g. Tri-State Disposal Inc. (“Tri-State”) was a waste management
company located in Riverdale, which had a contract with Riverdale to perform
garbage collection services between in or around 2012 and in or around 2019. Under
this contract, Tri-State was obligated to perform additional garbage collection
services in May 2018 for no extra charge (the “2018 spring clean-up”).

h. Company B was a waste management company that provided
garbage collection services.

1. Individual B was the Village Administrator for Riverdale.

Individual A operates Centennial for JACKSON’s Benefit

2. Although JACKSON and his wife owned Centennial on paper,
Individual A effectively operated Centennial for the benefit of JACKSON and his
wife, who had no experience in or knowledge of the trucking business. Individual A’s
Businesses financed Centennial’s operations with a loan and advanced money for
Centennial’s operating expenses, such as the costs of fuel, insurance, repairs, and
licensing, which was repaid from Centennial’s income. Centennial’s income came
from providing hauling services to Individual A’s Businesses, which deducted from
their payments to Centennial the expenses that Individual A’s Businesses incurred
in operating Centennial and payments on the loan, until Individual A forgave the

balance of the loan.

Case: 1:23-cr-00585 Document #: 1 Filed: 11/01/23 Page 3 of 11 PagelD #:3

3. The trucks that Centennial operated were originally owned by
Individual A, Individual A’s wife, or one of Individual A’s Businesses and transferred
or leased to Centennial. Individual A’s Businesses housed and maintained the trucks
for Centennial.

4. Drivers operating Centennial’s trucks were recommended and
interviewed by Individual A and hired by JACKSON with the assistance of Individual
A. Individual A’s Businesses assigned Centennial’s trucks to jobsites on a daily or
periodic basis to haul materials and debris for Individual A’s Businesses.

5. Individual A’s Businesses did not pay Centennial directly. Instead,
Company A-1 paid third-party entities, which after deducting a fee, passed on the
remainder to Centennial in the form of checks drawn on the accounts of the third-
party entities. The third-party entities’ primary role in the operation of Centennial
was to conceal payments from Individual A’s Businesses to Centennial.

6. JACKSON often obtained directly from Company A-1 the third-party
entity checks payable to Centennial, which were, in fact, payments from Individual
A’s Businesses. JACKSON paid Centennial’s drivers at the direction of Individual A.

7. JACKSON regularly communicated with Individual A and employees of
Individual A’s Businesses about Centennial’s operations, including employee hiring,
truck maintenance and repair, Centennial business records, and payments to
Centennial for work performed for Individual A’s Businesses. JACKSON was

dependent upon Individual A to obtain documents and records relating to the

Case: 1:23-cr-00585 Document #: 1 Filed: 11/01/23 Page 4 of 11 PagelD #:4

operation of Centennial. Neither JACKSON’s wife nor JACKSON’s accountant had
any role in the operation of Centennial.

Tri-State opposes Riverdale Issuing
a Special Use Zoning Permit to Individual A’s Company

8. In or around September 2017, Individual A’s company, Company A-2,
applied for a special use zoning permit to operate a recycling facility and waste
transfer station in Riverdale. Subsequently, at various public hearings, Tri-State
opposed Riverdale issuing the special use zoning permit to Company A-2.

Individual A assists JACKSON in replacing Tri-State with Company B

9. On or about March 20, 2018, JACKSON received an email from Tri-
State inquiring why Riverdale had not responded to Tri-State’s request to discuss
scheduling the 2018 spring clean-up. That same day, JACKSON forwarded Tri-Sate’s
email to Individual A, and asked Individual A, “Can you please assist me with this?”
After Individual A agreed to assist JACKSON, JACKSON responded, “Thx. I will let
Tri State know we are not using them.”

10. In or around March 2018 and April 2018, JACKSON caused Riverdale
to contract with Company B to perform the 2018 spring clean-up, which cost
Riverdale approximately $18,000 in additional charges. JACKSON caused
Riversdale to enter into this agreement despite Tri-State being under a contractual
obligation to perform the 2018 spring clean-up for Riverdale at no extra charge.

11. In or around May 2018, Individual A arranged for a meeting between
Individual A, JACKSON and a representative of Company B. In subsequent meetings |

in or around 2018, JACKSON and the Company B representative discussed Riverdale

4

Case: 1:23-cr-00585 Document #: 1 Filed: 11/01/23 Page 5 of 11 PagelD #:5

contracting with Company B to perform garbage collection services, instead of
renewing the contract with Tri-State. Individual A attended these meetings with
Jackson and the Company B representative, and served as an intermediary in the
exchange of information and documents between JACKSON and Company B.

12. IJnor around November 2018, JACKSON caused Riverdale to enter into
a contract with Company B to perform garbage collection services in Riverdale upon
the expiration of Tri-State’s contract in 2019.

The Tri-State Lawsuit

13.  Onor about February 23, 2018, Tri-State filed a civil complaint against
Riverdale and JACKSON in Cook County Chancery Court, Illinois, which lawsuit
was removed to the United States District Court for the Northern District of Illinois
on or about March 23, 2018, and captioned as Tri-State Disposal Inc. v. the Village of
Riverdale et al., No. 18 CV 2138 (the “Tri-State lawsuit”). Tri-State amended its civil
complaint on or about June 8, 2018, after Riverdale made known its decision not to
renew Tri-State’s contract.

14. The civil complaint, as amended, alleged that in November 2017,
JACKSON caused Riverdale to give preferential treatment to Company A-2, by
unlawfully causing Riverdale to issue a conditional use zoning permit to Company A-
2 that allowed Company A-2 to operate on an industrial lot in Riverdale, which
operations posed an environmental hazard to the public. Tri-State further alleged
that, after the owners of Tri-State spoke out at various public hearings against the

issuance of a special use zoning permit to Company A-2, JACKSON retaliated against

Case: 1:23-cr-00585 Document #: 1 Filed: 11/01/23 Page 6 of 11 PagelD #:6

Tri-State by refusing to renew its garbage collection contract with Tri-State, and by
other means. Tri-State sought an award of damages in excess of $260,000.

15. Onor about February 25, 2021, JACKSON participated in a deposition,
that is, he was placed under oath and answered questions posed by an attorney for
Tri-State.

16. The following matters, among others, were material to the deposition
and lawsuit:

e Whether JACKSON had any reason to be favorably biased toward
Individual A and businesses owned by Individual A and/or
members of Individual A’s family, or to be prejudiced against Tri-

State;

° Whether Centennial had any business dealings with companies
owned by Individual A and/or members of Individual A’s family;

° Whether JACKSON had knowledge of Centennial’s business
dealings with companies owned by Individual A and /or members

of Individual A’s family; and

° Whether JACKSON was involved with Riverdale’s hiring of
Company B to do the 2018 spring clean-up.

17. JACKSON communicated with Individual A immediately before his
deposition. During his deposition, JACKSON exchanged text messages with
Individual A regarding the topics covered during his deposition.

18. JACKSON’s answers to questions during the deposition were designed
and intended to conceal both Individual A’s extensive involvement in the operations
of Centennial, Individual A’s relationship with JACKSON, and JACKSON’s and
Individual A’s involvement in Riverdale’s replacement of Tri-State with Company B

to perform the 2018 spring clean-up.

Case: 1:23-cr-00585 Document #: 1 Filed: 11/01/23 Page 7 of 11 PagelD #:7

19. On or about February 25, 2021, at Chicago and Palos Heights, in the
Northern District of Illinois, Eastern Division,
LAWRENCE JACKSON,
defendant herein, was placed under oath prior to testifying at a deposition taken in
the Tri-State lawsuit, a proceeding before and ancillary to a court of the United
States, was advised that his testimony was subject to the penalties of perjury, and
knowingly made a false material declaration during his testimony by responding to
questions as follows:
[1] Q: Okay, so just to set the record straight, Centennial Holdings, owned by
you and your wife, may or may not have done or is doing business with
[Company A-2] or any company owned by the [Individual A’s last name]
family?
A: I don’t believe so.

Ok, but you said possible. Possibly.

There - There is a possibility, sir, but I’m not certain because I don’t
handle the day-to-day operations of the business.

Q: Okay. Who does?

A: That would be my wife, and also wherever we are dispatched to work at.

WHEREAS, in truth and fact, JACKSON knew that his wife did not “handle
the day-to-day operations” of Centennial or have any other involvement in running
the business, but rather that Individual A and employees of Individual A’s Businesses
handled the day-to-day operations of Centennial.
[2] Q: All right. Do you lease the trucks for a full month?

A: Yes.

Case: 1:23-cr-00585 Document #: 1 Filed: 11/01/23 Page 8 of 11 PagelD #:8

Q: How much?

A: My accountant handles that.

WHEREAS, in truth and fact, JACKSON knew that his accountant did not
“handle” or have any involvement in the leasing of Centennial’s trucks.

[3] Q: Okay. Does your business keep internal books and records?

A: My wife, she handles that as well.

Court reporter: I’m sorry, I didn’t hear that.

A: My wife handles that as well.

WHEREAS, in truth and fact, JACKSON knew that his wife did not keep or
“handle” Centennial’s “internal books and records,” but rather that Individual A and
employees of Individual A’s Businesses had control of the documents and records
generated in the operation of Centennial.

[4] Q: How did you come to know [Company B]?

A: They had introduction with me through my then Village Administrator,
[Individual B].

WHEREAS, in truth and fact, JACKSON knew that Individual B did not
introduce him to Company B, but rather that Individual A introduced JACKSON to
a representative of Company B for the purposes of discussing Company B replacing
Tri-State.

[5] Q: Okay. [Company B] gets hired to do the spring clean-up. Do you have
anything to do with that?

A: No. I did not.

Case: 1:23-cr-00585 Document #: 1 Filed: 11/01/23 Page 9 of 11 PagelD #:9

WHEREAS, in truth and fact, JACKSON knew that he, JACKSON, was

involved in the process of hiring Company B to do the 2018 spring clean-up;

[6]

Q:

Q:
A:

[Court reporter reading back plaintiff attorney's question]: . . . On the
record, the question is, why did the Village of Riverdale pay [Company
C] $18,000 to do the 2018 spring clean-up that Tri-State Disposal was
obligated to do under the contract — ready, willing, and able to do under
their contract — free of charge?

kk KE *

So with — with regards to the annual clean-up, I have never supervised
or managed the coordination of that program or project. That was given
to [Individual B]. [Individual Bj] opted to go with a different vendor. The
Board of Trustees upheld his decision and paid the bill.

And you didn’t have anything to do with it?

Not at all, sir.

WHEREAS, in truth and fact, JACKSON knew that Individual B did not “opt

to go with a different vendor” nor did Individual B make the “decision” to hire

Company B to do the 2018 spring clean-up;

In violation of Title 18, United States Code, 1623(a).

Case: 1:23-cr-00585 Document #: 1 Filed: 11/01/23 Page 10 of 11 PagelD #:10

COUNT TWO

The SPECIAL OCTOBER 2022 GRAND JURY further charges:

1. Paragraphs 1 through 15 of Count One are incorporated here.

2. On or about February 25, 2021, JACKSON testified falsely under oath
at a deposition taken in the Tri-State lawsuit, in an attempt to obstruct, influence,
and impede an official proceeding. In substance, among other things, defendant
JACKSON falsely testified about the following topics:

a. Whether his wife handled the day-to-day operations of Centennial
or had any other involvement in running the business;

b. Whether his accountant handled or had any involvement in the
leasing of Centennial’s trucks;

c. Whether his wife kept or handled Centennial’s internal books and
records;

d. Whether Individual B introduced JACKSON to Company B;

e. Whether Individual B recommended Company B;

f. Whether Individual B made the decision to hire Company B to do
the spring clean-up; and

g. Whether JACKSON was involved in the decision to hire Company

B to do the spring clean-up.

10

Case: 1:23-cr-00585 Document #: 1 Filed: 11/01/23 Page 11 of 11 PagelD #:11

3. On or about February 25, 2021, at Chicago and Palos Heights, in the
Northern District of Illinois, Eastern Division, and elsewhere,
LAWRENCE JACKSON,
defendant herein, did corruptly obstruct, influence and impede an official proceeding,
and attempt to do so, namely, the Tri-State lawsuit, in that the testimony described
in paragraph 2 of this Count was false;

In violation of Title 18, United States Code, Section 1512(c)(2).

A TRUE BILL:

‘ FOREPERSON

ACTING UNITED STATES ATTORNEY

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