FILED UNITED STATES DISTRICT COURT JAN 4 8 2019 ‘WESTERN DISTRICT OF TEXAS . ‘AUSTIN DIVISION Faas cal = ae UNITED STATES OF AMERICA, Crist. ACR 043 Bp | “ Courts One —Thice: US. | 1341 (Mail Fraud) YER GERATDPRALE, ‘ka Teceb Colas? Conia Four—Sie I8USC.§ tikia"Fn lowey.” 1345 Wie Freud) Deferdant Counts Seven Teh: 18 § 1956 (Money Laundsting) Counts Thirtwen—Fourteen: 18 US.C. § 1957 (Money Laundering) Counts Fifen, Seventeen, Ninctoeu: 18 CS.C. § O01()2) (False Staternents) Counts Steer, Biahteoa, Twenty: ISTISC. § 1519 (Falsfication of . Federal Records) DICT “The Grand Jury obra BACKGROUND ATERGATIONS 1. Atalimer mera to ths indieumont 2, Defendant KYLE GERALD PRALL was a resident of Austin, Tex in Us ¢- Westem Distr of Texas, 2. Person A worked ‘oc PRATT. ac dil marketer 4, Parson B worked for PRALL aw boctooper 5, "The Federal Eletion Coawaision (PEC) was un ugemsy of the United States Government responsible for'regulsting, smong other things, politcal committees formed to 1 support candidates for federal, lected ofice throug funirising wad expenditures 6 Duving the 2016 cleetion eyeie for the Offic ofthe President ofthe United Stara, politcal somites were required to reportto the FEC all cortebutions ard expendituresof $200 cor more, Revo of contibutions of $290 or more were required tn inslude the ameust ofthe conibution the Ate o? seep, ihe dons fll name and address, and the donr's ooeupation aad employer, Reports of expenditures of $200 or mare were required te include the amoan of the expen, the date of payment, the nar and adéoss of che payee, andthe purpose of the disbusement 7. Onor shout Desémber 30, 2015, PRALL registered the politesl committe “Fel [Bern with te PC for he slated purpose of suppocting Priskloutial Candidate A's ca acy for Tresidest of the United States. The mame of the commiee was Tate changed to “Socially Responsible Goverment,” although the website assoiaed with the coramiter continued to wse “Peel Bern” 8 On oF abou! fanny 19, 2016, PRALL segistered the pole commives HC¢Presidea” with the FRC. PRALL rogisterod HUMPresident for the stated purpose of supporting Presidental Candidate B's cand dacy for President ofthe United Sues. 9, Onor about Mavch 25, 3916, PRACT. opstered the poligoalcommitee “Trump “Vielory” wih the PRC, PRALL registred ‘rump Vielory for the stated pupose of suppating Presidential Candidate C's candidiey for President of the United States. The mame of the cemumitce was ater changed 1 “Make America Gest 10, "After segistsing cach polities cemmitee,2RALL opened o: causa fo bs epened a comespoading bank account for cack comitte a Finan Iitaion A. 11, PRAT opened LLCs and somesponding bank: accounts Financial Isto 3 2 and Co serve a8 anonymous shells (9 launder funds from che political committees and w distrib them lo PRALL. PRALL used a preesisting Limited Liability Compony (LLC and bank aconunt at Fiuaucial lastitution B to operate Fel Bata i ly and later used the account a final Iyer to furter launder moxey raised by che political committees and trans‘er it to PRALL'S personal accounts. Most af the baalcaccoun:s were closed shortly after the end cf the 2016election cycle, The LUCs and uscounts ere reflect below: DMF Wasting Sohations (DME) Febuary 2016, nancial Inaittion C NET Productions (XH) Financial Insticution B Decomiber 2076 Tauny 2016, Febsairy 2017 “Apex Marketing CAPE) Tine 2016 Tune 2015, Finareial | August 2017 Institution B HE SCHEME TO DEFRAUD 12, Beginning in December 2015 and continuing until zo later than August'2017, inthe ‘Western District of Texas and elsewhere, the defsndent, PRALL, did knowingly devise and infend to devise a scheme and art 4 dofiaud and to obtain money y means of material false and fiaadlont protons, representations, and promises; spifcally, PRALL solid coatibutions ‘om he general publi for multiple politcal eommites, incuding Fel Bem, FICAPresident, and Tromp Vietoy, based cn misrepresenttiors, including but not limited to, thatthe menoy cotaibvted by dons wel be sed to support candidates forthe Office ef the President ofthe ‘United States by: (1) paying for tanspotation for votes to the polls (2) paying for traning for ‘votunoee to make phone eas sul emvastneighbo-heods to support she respective candietes; (@)psving to help voters obtain appropriate identification dacuments; aud (raking conutions 3 ie to President! Candidate © end to ether organizations supporting his campaign, when in realty PRALL did no intend to, and didnot se the contibscons for any of these pusposes snd insta transfered much ofthe meney to himself hou: shum LLC accounts and used the other fama to generate ational eonsibusoasto his faudulent political commits. PURPOSES OF TITE SCHEME, 13, Wevas-a purpose ofthe scheme for he dofendat, PRALL, 10 eptich himseit by obtaining contbutions under fse pretenses ftom supporters of candidates forthe iis wf dae Presiden ofthe United States during the 2016 sesion oye 14. Teas a purpose of the scheme forthe defendant, PRALL, to conceal fom the pile, his donors, andthe FTC the fc hat he was regularly temsfecting ‘unde from his political committees te bank azcounts that he cont-lleé for his personal enrichent. 15) Thovas a purpose of the scheme for the defendant, PRAILL, to eoneect from the public, his donors, andthe FEC tha he was apending money contributed te his political committees directly from the politcal commitlee bauk accounts on personal expenses unralsted 10 the canviates or the 2016 presidential election MANNER AND MEANS : 16, ‘The manner ond meni by which the dofindant, PRALL, and othors erred outhe scheme intited, but were not imitedto the following: 17, Bogining in December 2015, 2RALL begen registering politcal somsattoss with the FEC for he sated purpose of soliciting contributions an malig exoeadies in Suppor. of candies forte Office ofthe Presiden: ofthe United Stes. 18. Beginning in January 2016, PRALL cstablished LLCs and opened bani ascounss in tho names ofthe LLCs to weesive taasfées ftom the political commitees to allow PRALL to 4 ‘ransfor political committee rooney to himself without being subject to FEC reporting requirements and public seratiny. wv. ing no Inet than Jacuary 2016, PRALL: (1) set up webshes solisitng contributions for is political cemmteos buted on misrepresentations as to how the money osld ‘be spent; 2) advertised the existance of his political committees ona, inlidingthngh itemet suc engines and social netvorking sites; and (8) posted extent o2 his politcal commitoe ‘wctsites to make them appear legitimate, 20, Peginaing in Jaasary 2016, PRALL transfered consbutions from the political commitessecounts to LLC bank accounts that he contlled, PRALL then tensered funds to his perunal checking und saving avcouuls fr his persoas use, eencealng from the FEC, the public, and the conttbutors to his politcal committers tat he was saking a lerge portion of the centers for hin personal enrichment. 21. ginning ao later than Februney 2016, PRALL. spent money dist from the oltical commits accounts on purely personal expenditucs, PRALL conse the ru nature cf many ofthese expenditures by reporting them io the FEC 1s legitimate expenses whea they ‘wore purely personal ia natre aa unrelated to fhe poi commites, ACTS IN FURTHERANCE OF THE SCHEME, Feel Bern 22. On or about December 30, 2915, PRATL caused w be filed an FEC Foor 1 Statement of Organization registering Fee] Bs sa political commits to snpport Presidential Cauidste A, On March 7, 2016, PRATL caused t0 bo Aled an FEC Form 1 Statement of Organization changiag the name of the political committeeto “Social'y Responsible Gevensnént.” s 23. No lator han January 2016, PRALL designed end launched a website at wow feelbemong, identifying the host organizelion as the Feel Born Committee to Elect eesietial Candidate A. TRALL solicited donations tough the website and falsely claimed “We are volunteers helping [Presidential Cenclidate Al win the US Presidential elzction and usher ine now govemment for the people by helping aise awareness with voters.” PRALLL also falsely represented: The donations willbe used pray to charter buss for wanspostaton to ving polls. This money will go dirty to cheering buses and payig “or fel to tansport vores to Presidential lection polls” 2A. Reween December 2915 and Tuly 2016, PRAT mised aver $300,600 in contsibutions to Feel Bern, Despite AL's representations, ofthis $300,000, PRAT. puid no expenses for tusportation, chartering buses, ot fuel, PRALL donate less thar: $8,000 to polities R, Stealing dhe Contributions 25, Retweer any 2,2016, and January 12,2017, on or about the dates listed below, PRALL transfe-red a wntal of $49,361.33 from Feel Bem to the NAT account und $41,405.81 (0 the DMF account, both of which he controlled, as se forth below Pe eETT Hee Dato TAOS STEN sanoIe ———*5R.570.00 Tam F690 aaa0Ie asm 572673016 $5,578.33 Sam $5,570.00 7asAM6 $4,563.34 | i STH BiRDO16 $9,653.09 jSpsroe | $4566.87 SIT016 39,463.98 Coin Sse Wiss $2,141 59 want 38,5896 Total $49,361.33 (Total SLATS 26, Th edition, between January and Tune 2016, PRALL pai himself a salary of approximately $46,153.80. 2. Additionally, PRALL used the debit ead for the politcal comrnitos’s bank account at Financial Tnsttnsicn A to pay forthe following personal expenditures: 4 1,167.64 fra two-night tay at The Plans Hotel & Spe in Miami Beach, Florida a Februmy 25,2616; $8,101.82 atthe ELEVEN nights in Mia, Hori for food, Hook lsh ted botle service, ané $1,470 for “elub dances performed by entertainers” on ebrancy 26,2016; 45,073.31 for teonight sty st the Oi Banton Crock Reser in Anti, Peas cv Marc 14,2916; and $728.4 for rum sovies and minibar charges, 8 deop-ssne esse, si ape cleaning fe, ducing ede nigh iy athe Omni Barton Cec Resort in Austin, Texas on Marc’ 18, 2016. C. False Statements to the FRC 28“ Onor about April 14, 20°6, PRALL, under the pscusdonym, “Jacob Collin,” for the purpose of reporting expenditures fe the FEC, falsely informed the crensurer of Feel Been, Person B, that the following were legitimate political committee expenditures for “meals & ‘entertainment: (1) $3,101.92 spent in Miami, Florida, on February 26, 2016, af the ELIEVEN nighichi> in Misexi for hookah, food, alcoho, and bolle service, and $1,470 for “club dances performed by entrti 1 all paid for between the hours of 1:44 am. ard $218 ama: and (2) {$710.79 for « deeo-tissue massage, pet-eleaning fe, room service, and mini-bar cha-ges during tay at the Omni Barion Creek Revert in Austin, Texas, fom March 14-17, 2018, PALL falsely cavegorized these expenditures knowing tht they lad been entirely personal in nature and ‘knowing that they would falsely reported to the FRC. HCaPresiden A. Sollettations 29, Onor about January 19, 2016, PRALL caused to beflled az FEC Form | Statement of Organization registering “IC4President” as « politcal committee to support Presidential Candidate B. 30, No later than April 2015, PRALL designed and’ launched a website at wor heforpresiden.ong, identifying the host organization as the Committee to Blect [Presents Candidate Bl, PRATT. solicited Conations through the website and falsely claimed: “We are vlrteers helping [Peesidrtial Candidate B] win the US Presidential election and sherin a wy govemment for the people by helping raise awaiencas with voters.” PRALL also falsely represented: “Your contribution goes diectly toward paying for training voluateees to knock on doors, make pkone calls and spread the wond about [Presidential Candidate B's movement, I 8 fse hops pay for on ntintive to help votes obtain che appropriate ID and tunsporation to voting sin” 31, Between January 2016 snd November 2016, PRALL raised over $73,000 in contribuioas to HCArssient, Despite PRALLs representations, his 73,000, PRA paid ‘no expenses for taining volunteers, helping veters obtain ientfeation, or aa or providing ‘eansportation te vating fillies, PRALL donated los than $1,100 wo politica causes, Stealing the Contributions 32, Between April 29,2016, and December 5,2016, on or about the dates listed belows, PRALL transferred «total of $34,543.77 fom L1C4President tothe NHT account and $7,754.88 (o the DMF account, bulk of vil le controle, as st fo:th below: +2 ST EEE: rae on G Peau i oe ae i Date “Arron, Date “AOU anom016 Faso noe Si. aaa $6,742.30 warns ST 1182016 $9,784.50 ‘Total $7,753.88 iiiwan 3435645 [Taseois | $6,096.52 Total $34,588.77 53, Additionally, PRALL used the debt card forthe politica! committee's hank secount at Financial insttaton Ato pay forthe following personal expouliiues: ‘$9540 forroenhrpsvfne For PRALL and bis gl end wo Jacksonville, Pride an Agr 25,2016, $460.36 for om sevice, drinks a the 1b bar, and dines >the Orn ol in Dalle, Texas en May 5, 2016; and . . ‘$812.43 far oundcp safe to Belize on Sime 29,2018, . Fate Statements the FEC 34 Onor about June 29,2016, PRALL, forthe purpose of reporting expedite to bookkeeper of HO¢Prsident, Person B, tat tho ‘lowing were rote political committee expenditures for “iavel expenses: $460.26 spent in Malas, Texas, fon May 3, 2016, for room service drink atthe lobby bas, and dinner at he hotel zestaurant PRALL falsely categorized these expenditures Inowing that they had been eutiely personal in nature and Yrowing that they woud he falsely reported to the FEC. 35, Onorabout Match 22, 2016,PRATI, cased tobe filed an FRC Form 1 Statement of Organization registering “Trump Victory” as polieal committee to support Presidential Candidate C. On Miy 24, 2016, PRALL, cavod fo be Sled ah FEC Form 1 Statement of Crenizaton changing the name ofthe plies! commteeto Mase Amerta Grea" 36, No ster than Jane 2016, PRATL designed of eaused to be designed and Inuncked cor caused 1 be launched a website seve rumovitoy. or, iemfjing the host organization es the Commitee to lest Presidents Canfidte C], PRALL solisited donations through the vwesic end fly lime: “Weer a group of vountor from ll was of ie who are Leong fora setl change in leadeship and we bsieve [2zesidetial Canidae C) ean deliver” PRATT. tse falsely represented: “ ako donate the maximum allowed Tegal Hits divcty 0 [Presidential Cada C] aad othe: organization md nonpefits Cat are supposing Prosidertish candidate C's semysign for President.” 37. Between Marsh 2016 and November 2016, PRALL raised over $165,000 in 10