Superseding Information — United States v. Hanalei Aipoalani, District of Columbia (Document 9)

Summary

A Superseding Information in United States of America v. Hanalei Aipoalani, Criminal No. 1:20-cr-00286, in the U.S. District Court for the District of Columbia, filed March 15, 2021 as Document 9. Count One charges federal programs embezzlement under 18 U.S.C. § 666(a)(1)(A), alleging the defendant obtained more than $5,000 in Non-Profit 1 funds by falsely representing they were needed for its AmeriCorps program. Count Two charges federal programs bribery under 18 U.S.C. § 666(a)(1)(B), alleging that as CARES Act Program Administrator for the Department of Community Services of the City and County of Honolulu, managing the $166 million allotted under the Coronavirus Relief Fund, the defendant corruptly solicited a thing of value on or about September 16, 2020. Forfeiture is sought of a 2014 Ford Fusion Hybrid and a money judgment of $527,000.

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“Superseding Information — United States v. Hanalei Aipoalani, District of Columbia (Document 9).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-1-20-cr-00286-dkt-9-d-d-c-7a67b348e2/, SHA-256 2245541a088ab89e5d537ced114bf58de229dc61f2ba109c0d9fb0dc38697263.

Full text

Case 1:20-cr-00286-RBW Document 9 Filed 03/15/21 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA, :
:
v. : Criminal No. 1:20-cr-00286
:
HANALEI AIPOALANI, : VIOLATIONS:
: 18 U.S.C. § 666(a)(1)(A)
Defendant. : (Federal Programs Embezzlement)
:
: 18 U.S.C. § 666(a)(1)(B)
: (Federal Programs Bribery)

SUPERSEDING INFORMATION

The United States of America charges that:

COUNT ONE

1. Between in or about May 2018 and in or about May 2019, NON-PROFIT 1 received

benefits in excess of $10,000 under a Federal program involving a grant, contract, subsidy, loan,

guarantee, insurance, or other form of Federal assistance.

2. From in or about May 2018 to in or about May 2019, within the District of

Columbia and elsewhere, the defendant, HANALEI AIPOALANI (hereinafter “AIPOALANI”),

while an agent of NON-PROFIT 1, did embezzle, steal, obtain by fraud, and otherwise without

authority knowingly convert to the use of any person other than the rightful owner and intentionally

misapply property that was owned by and under the care, custody, and control of NON-PROFIT

1 and was valued at $5,000 or more, that is, AIPOALANI obtained more than $5,000 in NON-

PROFIT 1 funds by falsely representing the funds were required to support NON-PROFIT 1’s

AmeriCorps program, when, in fact, AIPOALANI converted the funds to his and others’ personal

use.

All in violation of Title 18, United States Code, Section 666(a)(1)(A).
Case 1:20-cr-00286-RBW Document 9 Filed 03/15/21 Page 2 of 3

COUNT TWO

3. At all times material to this superseding information, the Department of

Community Services for the City and County of Honolulu was an agency of a local government

that received federal assistance in excess of $10,000 during the one-year period beginning on or

about January 1, 2020 and ending on or about December 31, 2020.

4. Defendant was an agent of the Department of Community Services, to wit the

CARES Act Program Administrator, whose duties included managing the $166 million allotted to

the Department of Community Services under the Coronavirus Relief Fund.

5. On or about September 16, 2020, in the District of Hawaii, Defendant did corruptly

solicit, demand, accept and agree to accept a thing of value from a person, intending to be

influenced and rewarded in connection with a transaction and series of transactions of the

Department of Community Services involving $5,000 or more.

All in violation of Title 18, United States Code, Section 666(a)(1)(B).

FORFEITURE ALLEGATION

1. Upon conviction of Count One, charging an offense in violation of 18 U.S.C.

§ 666(a)(1)(A), the defendant shall forfeit to the United States any property, real or personal, which

constitutes or is derived from proceeds traceable to the offense, pursuant to Title 18, United States

Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c). The United States

will also seek the forfeiture of the following specific property:

a. 2014 Ford Fusion Hybrid, with Vehicle Identification Number

3FA6P0LU5ER256328; and

b. A MONEY JUDGMENT in the amount of $527,000, equal to the value of any

property, real or personal, constituting or derived from proceeds traceable to the

offense.
2
Case 1:20-cr-00286-RBW Document 9 Filed 03/15/21 Page 3 of 3

SUBSTITUTE ASSETS

2. If any of the property described above, as a result of any act or omission of the

defendant:

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 of America shall be entitled to forfeiture of substitute property pursuant to Title

21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section

2461(c).

CHANNING D. PHILLIPS
ACTING UNITED STATES ATTORNEY

By:
LESLIE A. GOEMAAT
MA Bar 676695
Assistant United States Attorney
Fraud Section
U.S. Attorney’s Office
555 4th Street, N.W., 5th Floor
Washington, D.C. 20530
(202) 803-1608
Leslie.Goemaat@usdoj.gov

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