Indictment — United States v. Christopher Chapman (E.D. Ky.)

Summary

An Indictment in United States of America v. Christopher Chapman, Case 7:24-cr-00004-KKC-EBA, in the U.S. District Court for the Eastern District of Kentucky, Southern Division at Pikeville, filed April 18, 2024 as Doc 1. Count 1 charges theft concerning programs receiving federal funds under 18 U.S.C. § 666(a)(l)(A) against the Fire Chief of Blackberry Volunteer Fire Department. It states that Pike County received $11,241,735 in American Rescue Plan Act funding and that the Fiscal Court issued the department a $25,000 grant on June 16, 2022 and a $25,000 grant on July 18, 2022. The grand jury alleges that the department prepaid for equipment from Rural Public Safety Equipment, LLC, a company Chapman organized, and that Chapman withdrew cash from its account for personal use instead of filling the orders. The penalty page lists imprisonment for not more than 10 years.

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“Indictment — United States v. Christopher Chapman (E.D. Ky.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-7-24-cr-00004-dkt-1-e-d-ky-4e2e79d56e/, SHA-256 d73eb04711054fd603004887d14716e416f9b822500967decb798edaaac9ea9a.

Full text

Case: 7:24-cr-00004-KKC-EBA Doc #: 1 Filed: 04/18/24 Page: 1 of 5 - Page ID#: 1

UNITED STATES DISTRICT COUR¥slern District of Kentucky
EASTERN DISTRICT OF KENTUCKY FILED
SOUTHERN DIVISION APR 18 2024
PIKEVILLE AT LEXINGTON
Robert ft Carr
OLl;;l'IK u.e. Ql6TRIOT OOIJRT
UNITED STATES OF AMERICA

V. INDICTMENT NO. 7: Z4 Ct2 • 4. DIB

CHRISTOPHER CHAPMAN

* * * * *

THE GRAND JURY CHARGES:

BACKGROUND

1. At all relevant times, CHRISTOPHER CHAPMAN was the Fire Chief of

Blackberry Volunteer Fire Department (BVFD) located in Pike County, Kentucky.

BVFD was funded by both the Kentucky Fire Commission, a state agency, and Pike

County local government. In this capacity, CHAPMAN was an agent of the local

government of Pike County and an agency thereof(Blackberry Volunteer Fire

Department), within the meaning of 18 U.S.C. § 666(a)(l ). At all relevant times,

CHAPMAN was a resident of Pike County, Kentucky.

2. In March 2021, Congress enacted the American Rescue Plan Act (ARPA)

to, in part, support communities and local governments which were struggling due to the

COVID-19 pandemic. As part of ARPA, the federal government distributed emergency

funding to local governments to maintain vital local services. The local government of

Pike County, Kentucky received $11,241,735 in ARPA funding.
Case: 7:24-cr-00004-KKC-EBA Doc #: 1 Filed: 04/18/24 Page: 2 of 5 - Page ID#: 2

3. In the one-year period covered by this Indictment, the local government of

Pike County, Kentucky, including BVFD, received benefits in excess of$10,000 under a

federal program involving a grant, contract, subsidy, loan, guarantee, insurance, and other

form of federal assistance, within the meaning of 18 U.S.C. § 666(b).

4. On April 11, 2022, CHAPMAN, the sole organizer and member of Rural

Public Safety Equipment, LLC (RPSE), registered RPSE with the West Virginia

Secretary of State. CHAPMAN informed members of the Board of the BVFD that he

could obtain fire safety equipment at cost from a safety equipment company. As a result,

in April 2022, BVFD began purchasing equipment from RPSE.

5. On May 8, 2022, CHAPMAN, acting as the Fire Chief ofBVFD, applied

for part one of the Pike County Fire/Rescue Recovery Grant Application to obtain

funding for turnout gear. On June 16, 2022, Pike County Fiscal Court issued a $25,000

grant to BVFD for turnout gear.

6. On July 7, 2022, CHAPMAN, acting as the Fire Chief ofBVFD, applied

for part two of the Pike County Fire/Rescue Recovery Grant Application to obtain

funding for equipment and building maintenance. On July 18, 2022, Pike County Fiscal

Court issued a $25,000 grant to BVFD for equipment and building maintenance.

7. During the relevant period, BVFD prepaid and ordered fire and safety

equipment from RPSE. Instead of using the prepayments from BVFD to fulfill the fire

and safety equipment orders, CHAPMAN withdrew cash on numerous occasions from

the RPSE bank account for his personal use.
Case: 7:24-cr-00004-KKC-EBA Doc #: 1 Filed: 04/18/24 Page: 3 of 5 - Page ID#: 3

COUNT 1
18 U.S.C. § 666(a)(l)(A)

8. Paragraphs 1 through 7 of this Indictment are re-alleged and incorporated

by reference as if set fo1th fully herein.

9. From on or about May 15, 2022, through on or about May 14, 2023, in Pike

County, in the Eastern District of Kentucky, and elsewhere,

CHRISTOPHER CHAPMAN,

being an agent of an organization, said organization receiving more than $10,000 of

federal funds in the same twelve month period under a federal program involving a grant,

contract, subsidy, loan, guarantee, insurance, or other form of federal assistance,

knowingly embezzled, stole, obtained by fraud, otherwise without authority knowingly

converted to the use of a person not to the rightful owner, and intentionally misapplied

property valued at $5,000 or more and owned by and under the care, custody, control of

the local government of Pike County and Blackberry Volunteer Fire Department, all in

violation of 18 U.S.C. § 666(a)(l)(A).

FORFEITURE ALLEGATION
18 U.S.C. § 981(a)(l)(C)
28 u.s.c. § 2461

1. By virtue of the commission of the offense alleged in Count 1 of the

Indictment, CHRISTOPHER CHAPMAN shall forfeit to the United States any and all

property, real or personal, which constitutes or is derived from proceeds traceable to the

violation(s) of 18 U.S.C. § 666(a)(l)(A). Any and all interest that CHRISTOPHER
Case: 7:24-cr-00004-KKC-EBA Doc #: 1 Filed: 04/18/24 Page: 4 of 5 - Page ID#: 4

CHAPMAN has in this property is vested in and forfeited to the United States pursuant

to 18 U.S.C. § 98l(a)(l)(C) and 28 U.S.C. § 2461.

2. The property to be forfeited includes, but is not limited to, the following:

MONEY JUDGMENT:
A forfeiture money judgment in the amount of proceeds obtained by the
Defendant as a result of the offense charged in Count 1.

3. If any of the property listed above, as a result of any act or omission of the

Defendant(s), (A) cannot be located upon the exercise of due diligence; (B) has been

transferred or sold to, or deposited with, a third party; (C) has been placed beyond the

jurisdiction of the court; (D) has been substantially diminished in value; or (E) has been

commingled with other property which cannot be divided without difficulty, the United

States shall be entitled to forfeit substitute property pursuant to 21 U.S.C. § 853(p).

• ATRUEBILL

~ SJ:.-~
CARLTON·8. SHIER IV
UNITED STATES ATTORNEY
Case: 7:24-cr-00004-KKC-EBA Doc #: 1 Filed: 04/18/24 Page: 5 of 5 - Page ID#: 5

PENALTIES

COUNT 1: Imprisonment for not more than 10 years, a fine of not more than
$250,000, and supervised release for not more than 3 years.

PLUS: Mandatory special assessment of $100 per count.

PLUS: Restitution, if applicable.

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