27-page indictments details alleged bribes

White Castle Mayor Maurice “Big Moe” Brown and his brother, Police Chief Mario D. Brown improperly used the Town of White Castle “to enrich themselves through bribery,” the 27-page federal indictment issued last week alleges.

Count 1 of the indictment, charging a violation of the Racketeer Influenced and Corrupt Organizations (RICO) Act, alleges a “pattern of racketeering activity” and nine instances of public bribery:

On October 8, 2008, Maurice Brown accepted New Orleans Saints football tickets worth $1,671 from “Businessperson B,” representing Cifer 5000 “in exchange for agreeing to use his official position to ensure a contract between the town and Cifer 5000.”

On November 25, 2008, Maurice Brown agreed to accept tickets to a Bayou Classic football game from “Businessperson A” in exchange for providing an official letter stating the Town of White Castle was committed to contracting with Cifer 5000 to help   generate $2 million to $3 million in private funding for the company, and on November 26, 2008 accepted payment of $215 for a luxury hotel in New Orleans from Businessperson B in exchange for providing the investor letter.

On October 21, 2009, Maurice Brown agreed to accept Saints tickets worth $1,155 from Businessperson B in exchange for his writing an official letter of support for a request for a U. S. Environmental Protection Agency grant of $3 million.

On October 22, 2009, Mario Brown agreed to accept Saints tickets worth $1,137 from Businessperson B in exchange for providing confidential law enforcement information on two unidentified individuals.

On November 3, 2009, Maurice Brown agreed to accept Saints tickets worth $1,385 from Businessperson B in exchange for getting his brother to provide confidential law enforcement information on a third individual.

On January 20, 2010, Maurice Brown accepted $500 in cash from Businessperson B in exchange for supporting the town's contracting with Cifer 5000.

On January 20 and 21, 2010, Mario Brown agreed to accept cash and Saints tickets valued at $1,028 from Businessperson B in exchange for providing confidential law enforcement information on three more individuals.

On February 9, 2010, Mario Brown agreed to accept money and basketball tickets worth $290 to provide confidential law enforcement information on three more people.

On April 21 and 22, 2010, Mario Brown agreed to accept $500 in cash from Businessperson B to write a false official letter to a state prosecutor in New Haven, Connecticut, seeking lenience for an individual Brown believed was facing drug charges.

On June 10, 2010, Maurice Brown agreed with Businessperson B to accept 10 percent of the profits Cifer 5000 made from a contract with the town.

Counts 2-5 accuse Maurice Brown of mail fraud involving the Cifer 5000 in “a scheme to defraud the citizens of the Town of White Castle of their right to [his] honest services in the affairs of the Town of White Castle” and to defraud potential investors.

The indictment alleges Maurice Brown caused the investor letter to be mailed from White Castle to Dallas, the EPA letter to be mailed from White Castle to New Orleans, four tickets to a Saints game to be sent by Federal Express from Metairie to White Castle Town Hall, and a $500 money order to be mailed from Metairie to White Castle.

The description of Counts 2-5 provided additional detail on the alleged transactions:

In October 2008, at the invitation of “Public Official A,” Maurice Brown met with the Cifer 5000 businesspeople at a condominium in New Orleans, along with Public Officials A, B and C.

“During the meeting, Public Official A obtained $2,000 in cash from Businessperson A and subsequently provided some of the cash to Maurice Brown,” the indictment read. “In addition to cash, Maurice Brown and the other public officials also accepted tickets to a football game...and rooms at a luxury hotel worth a total of $2,293 from the businesspeople.”

On October 9, 2008, Maurice Brown asked how much the Saints Tickets cost, since he intended to sell some of them. Businessperson B said they cost some $1,600. According to the indictment, Brown replied, “We gonna take care of you on the other end [reference to the Cifer 5000...now the only other time I'm gonna call you back for some other tickets is when Dallas plays the Saints.”

On October 10, 2008, Maurice Brown complained to Businessperson B the tickets had not arrived. “After being assured that the tickets would be arriving later that day, Maurice Brown stated that Public Official A already had something in motion regarding the implementation of the Cifer 5000in their municipalities and that Businessperson B would be taken care of. Businessperson B responded, 'and I'm going to take care of you, you ain't got to worry about that.'”

On November 19, 2008, Maurice Brown agreed to provide the investor letter to Businessperson A in exchange for tickets to the Bayou Classic football game. A week later, he “solicited Businessperson B to pay for his luxury hotel room in New Orleans, while informing Businessperson B that he had the [investor] letter ready” for them. When Businessperson A arranged to pay for the room, Brown said he had mailed the official letter, on his official letterhead, later that day.

In the letter quoted in the indictment, the mayor said he was committed to working towards a contract with Cifer 5000.

“Also, I have presented this issue to the Town Council and each of its members has expressed support for engaging your services,” the letter read.

(Members of the Board of Aldermen said the mayor never proposed the contract to them.)

In a discussion of football tickets on January 20, 2010, Businessperson B said, “This is what I can do. I can either get you a nose bleed ticket, cause they gonna cost $500, but me personally, I'd rather give you the $500 and you do whatever you want.” In response, the indictment said, “Maurice Brown chose the $500 and asked Businessperson B to mail the money to his residence.”

On June 9, 2010, Maurice Brown met with Businessperson B and Public Officials A, B and C at a Baton Rouge restaurant.

“During the meeting Businessperson B explained that Public Official C would be receiving 10 percent of the Cifer 5000's profits made in that official's municipality because of Public Official C's support for the Cifer 5000,” the document said. “Maurice Brown indicated to Businessperson B that he wanted the same arrangement.” The next day Businessperson B allegedly agreed to the deal with Brown.

The wire fraud transactions, Counts six through nine, involved the Browns' scheme to obtain confidential information from the Federal Bureau of Investigation in exchange for game tickets.

In one instance, the indictment said, faxed information reflected that Mario Brown had accessed the information through the FBI's national crime information system that contained a statement that the information was for “Law Enforcement Use Only.” In a conversation about the transaction, “Maurice Brown expressed concern to Businessperson about the possibility of law enforcement wiretapping his telephones and tracing his emails, including any tickets that Businessperson B emailed to Maurice Brown.”

In another instance, when Businessperson B asked for had copies of some confidential information, Mario Brown said he would provide them in change for B's buying Mardi Gras beads for him.

“I'll give you the money...I'm not going to buy the throws. I'll just give you the money,” Businessman B replied, and Mario Brown ageed, the indictment said.

Later, Businessman B asked Mario Brown if he would accept basketball tickets instead of the $500 for beads. “You said you were going to hood me up pretty good, drop me some money, and let me go get the stuff,” the police chief is quoted as saying. Businessperson B then offered $200 or $300 or the tickets. “Aw man, why can't I have my cake and eat it too?” Mario Brown is quoted further.

Count 10, a wire fraud involving a letter to a Connecticut prosecutor, accuses Mario Brown in a scheme “to obtain cash from Businessperson B in exchange for using [his] position as chief of police to fraudulently obtain leniency for Businessperson B's nephew, who had an upcoming bond hearing drug charges in Connecticut.

According to the indictment: Businessman B offered the police chief $500 to write a character reference for the nephew. “I need a new truck, but I guess that will do,” Mario Brown is quoted as saying. When the two arranged to meet in Gonzales to exchange the cash and the letter, Mario Brown instructed B to bring cash.

“You bring green huh? All green, I don't want to paper, I mean no one piece of paper,” the police chief is quoted.

“I'm always going to give you cash,” Businessperson B replied. “I ain't gonna give you no paper trail. Are you kidding me?”

In the character reference letter, Brown allegedly writes that he has known the nephew throughout his childhood when he visited his grandmother in White Castle, and was shocked to hear of his arrest.

“Contrary to the representations in the letter, Mario Brown did not know [the nephew], who had no relatives in Louisiana, much less an grandmother in White Castle,” the indictment said.

Counts 11 through 20 allege use of an interstate facility in aid of racketeering in connection with alleged bribes.