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JlL-23-2007 09 :32 FRa1:XEROX 2102264123 TO :2e23530819 P.2 Filed 1 -..l3 -0 1 CIeri<. U. S. Distrld Court By Wastem Dis O;fTex:;., Deputy UNI TED STATES OF VS. JOHN C OCKERHAM 554 Graham Ro ad Fort Sam Hous ton , 'I'e xa e 78234 CRIMINAL COMPLAI NT Case No . SA- 0 7-492 M I, t he undersign ed c om pl aina nt , be i ng du ly swo r n, s ta te t he follo wing is t rue an d co rrect to the best of my kn o wl edge a nd belief. Count One ; In or about 2005 and 2006 in the Western Di stric t of Te xas a nd elsewhere , Defe nda nt John Cocker ham, be i ng a public off icial of th e United States, corruptly d id dema nd . see k, receive, and accept a thing of va l ue . pe rsonally a nd for other persons in re turn fo r bei ng inf luen ced in the performanc e of an o ffi c ial act and b eing influenced to commit and aid in c ommi tt ing, c oll uding, and allowi ng a fraud on the Uni ted St ates in violatio n of Title 18 , United States Cod e, Section 20 1( b) (2) ; Co unt Two: In or about 2 005 and 20 06 in the Western Dis t rict of Te xas and el sewhere, Defendant John Co cke rh am did know ing ly consp ire, confederate and ag ree wi th o ther per s ons known and u nknown to commit of fenses aga inst the United St at es, that i s, to direct ly and ind irect ly . c orr upt ly de mand, seek, receive, ac cept, and agre e to re ce i ve and accept th ings of value, tha t i s, c as h, fr om gove rnmen t c on tract ors in r etu rn for b eing influenced in the pe rfo rman ce of off ic ia l a ct s; an d wi ll f ully did co n spi re and ag re e w it h ot he rs to def raud t he U nited St a tes an d the U.S. Army by hi n de ri ng an d i mpedin g t he l a wf u J fu nctio ns of the U.S. A. rm y in t he p roc ur e me nt of good s and services a nd in fu rt he ran ce of the co nspir ac y and to e ffect the objects and purpo s es thereof the De f e nd a n t d id per form ove rt acts , incl Uding, but not limite d to t he De fenda nt's prepa ration in 2 00 5 of a handw ri tt en ledger to keep track of mil lions of dollars in b rib e p ayruents accepted by th e Defend an t, all in v iolation of Ti t le IB, Uni t ed States Code , Sect ion 371; Count Three: In or about 2005 and 2006 in t he West er n District of Texas and else where, Defendant Joh n Cockerham w illfully did cons pire and agree with othe rs to c onduct financial transacti ons w hich in fact in vo lve d the proceeds of unl awful activit y, that is , the Acceptanc e Of Bribes By A Publ ic Official in violation of Tit le 18 U.S. C. 2 01 (b )( 2) , while knOW ing that t he transactions we r e designed in whole a nd in part to co nceal and disgU ise the nature, l ocation , s ource, ownership, and c on trol of the pro ceeds of specif i ed unlawful activity, and wh ile kno wi ng that the pr op e rty involved in su ch 'i3.P SAction s ' i. ··" l.'I/ r_ " t" 'lle U '" ' Lo: rtlty . . nl il l' ,- YUrt D "('IUly

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JlL-23-2007 09 :32 FRa1:XEROX 2102264123 TO :2e23530819 P.2

Filed 1 -..l3 -01CIeri<. U. S. Distrld Court

By Wastem DisO;fTex:;.,Deputy

UNITED STATES OF &~ERICA

VS.

JOHN COCKERHAM554 Graham Road

Fort Sam Hous ton , 'I'e xae 78234

CRIMINAL COMPLAI NT

Case No . SA- 07-492M

I , t he undersigned c omplainan t , be i ng duly swor n, s ta t e t hefollowing is t rue and correct t o the best of my knowle d ge a ndbelief.

Count One ; In or about 2005 and 20 06 i n the WesternDi strict of Texas a nd elsewhere , Defendant John Cockerham, bei nga public official of the United States, corruptly d id demand .see k, r e c e i ve , and accept a thing of va l ue . personally a nd forother persons i n return fo r bei ng inf luenced i n the performanceof an offi c ial act and b eing influenced to commit and aid inc ommi tt ing, c ollu d i ng , and allowing a fraud on the Uni ted Statesin violation of Title 18 , United States Code, Section 201 (b) (2) ;

Count Two: In o r a b out 2005 and 2006 in the WesternDis t rict of Texas and elsewhere, Defendant John Co cke rha m didknow ing ly conspi r e , confederate and agree wi t h o ther pers onsknown and u nknown t o commit offenses aga inst the United St ates,that i s, to direct ly and indirectly . c orrupt l y demand, seek,receive, accept, and agree t o recei ve a nd accept t h ings o f value,tha t i s, c as h, from gove rnmen t c ont r a c t ors i n r etu rn for b eingi n f l ue n c e d in the pe rformance of offic ia l a ct s ; and wi ll f ully didconspi r e and ag ree with o t he rs to def r a u d t he United Sta tes andt h e U.S. Army by hi nde rin g and i mpeding t he l a wf u J function s ofthe U.S. A. rm y in t he p rocure me nt o f goods a nd services a nd i nfu rt her a n ce o f the con s p i r acy a nd to e ffect the objects andpurpos es t h e r e o f the De f e nd a n t d id per form overt acts , incl Uding,but no t limited t o t he Defenda nt's prepa ration in 2 00 5 of ahandwri t t en l e dg e r t o keep t r a c k of mil lions of dollars in b ribepayruents accepted by the Defendant, all in v iolation o f Ti t le IB,Uni t e d States Code , Sect ion 371;

Count Th r e e : In or about 2005 and 2006 in t he WesternDistrict of Texas and elsewhere, De f e n d a n t John Cockerhamwillfully did consp i r e and agree with others to c onduct financialtransactions which in fact inv o lved the proceeds of sp~cified

un l a wf u l activit y , that is , the Acceptance Of Bribes By A Publ icOf f i c i a l in violation of Tit le 18 U.S. C. 201 (b ) (2) , while knOWingthat t he transactions we r e designed in whole a nd in part t ocon c e a l and disgU ise the nature, l ocation , s ource, ownership, andcontrol o f the proceeds of specif i ed unlawful activity, a nd whileknowi n g that the prope rty i nvo l ve d in s u ch financ~a:l! , 'i3.PSActions

' i. ··" l.'I/ r _ "t" 'lle U '" ' Lo: rtlty.

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J LL-23-2121137 1219 :32 FROM : XEROX 21132264123 TQ=202353 121819 P.3

r ep r esented the proceeds of spme f orm of un lawful activity, <:l.n din fu rtherance of the can s p i r D. c y a n d t o e ff e c t the obj ects andpurposes the reof, thl:! Defenda nt did per fo rm overt acts ,including, bu t no t l i mi t ed t o the Defen dant' s di r e c tion t o h)swife in 2 0 05 to t ravel t o Du bai wit.h anothe r woman fo r th(lpur pose of plac i ng curre ncy in a s afe deposit box, all i nv i o l a t ion o f Tit le 18 , United St a tes Code, Sec ti on 1956 (h ).

I further state that I am a Spec ial Agent of the U. S. ArmyCri mi nal I nvest i gat i on Division and that this c ompla i nt is b a s edon the fa c ts se t forth in t he "Af f i davit I n Su pport Of Warran t sTo Arre s t and To Search" wh i c h is a t t a c hed to thi s complai nt an dincorpor a t ed f o r a ll purposes. ~ ~~~ __

" ~~:'~"YO" .",,",Swo r n to belore me and s ubscr i bed in my presence ,

D"~ 2..1 ( 2..00/

Si gn;:" t ure o f u.s . Milqistra t e J udg e

Ptm:~~. Magistrat e

a t San Ant oni o , Texas

J udge

JUL- 23 -2007 09 :38 FROM: XEROX•

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21132264123

D ISTRICT Of

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Texas

P .9

In the Malter of th e Search of(No....., oddreQ or brief 6cscliplioll . f penon. prllpcrty cr ~,is<:llIO be larched)

554 Gra ham RoadFort Sam Houston Army PostSa n Antonlo, TX 78234

APPLICAnON AND AFFIDAVITFOR SEARCH WARRANT

Case Number: SA-07-489M

I, R<:Iy A. Rayos

I am a(n} Special Agent, US Army Cnminallnvestigation Commandom~;ol Ti ~"

being duly sworn depose and say:

an d ha ve reason to bel ie ve

that 0 on the pers on of o r QJ on the property or premises kno wn as (name, description and /or locat ion )

554 Graha m Road, Fort Sam Houston Army Post, Sa n Antonio, TX 78234, more fully described in Attachment A

in th e West ern D istrict of Texas

there is now conce aled a ce rtain person or property , nam ely (de.scribe!h e p<;rson orpmpc:ny 10 be ~",ed)

See Attac hment B

which is (IIO.le one ormore bale, for snreh ond &<;;l.ur,,~ f.nII Urll;\er Rule 4 1(b) oC lh<: l'ed emJ Rule. orCrlmlnftl l'roc..d"",)

trutts, evidence , lind instrumen talitie s of crimes against the United State s

co ncern ing a violation of Title , 8 United States ecce. Section( s) 201 . 371 and 1956(h)

The fac ts to support a find ing of proba ble ca use are as follows:

See Attached Aflidavit

Continued on the attached sheet and made a part hereof

Sworn to before me and subscribed in my presence,

ny . I f Il'~ , ' r i_~l i l' l. f cc rnfy.

k, U, s. Dl$lrLi.: Co urt

Pamela A. Malhy U.S. Mag istrate

at San An ton ioCily

"t.,t;6~4\

TexasSlllle

JUL-23 -2007 09:38 FROM: XEROX 2102264123 TO: 2023530819 P .l0

AFFIDAVIT TN SUPPORT OF WARRANTS TO ATIRJ;:5T AND 1'0 SEATlCH

I, Ray A. Rayos, the undersigned Affiant, being first duly sworn hereby state as follows:

L b ffIANT

1. I have been a Special Agent with the U.S. Army C'Anny"), Criminal I nvestiga tion

Division ("ero"), Major Procurement Fraud Uni t for 6 years. Prior to becoming a civilian agent,

I was an active duty ClD agent. A:; a ClD Special Agent, I investigate allegations of fraud, waste

and abuse related to Army contracting. During my tenu re as a Special Ageut.J have bee"

involved in investigations related to fraud, bribery , and money laundering and I am familiar with

the types ofbehavior individuals utilize when they have defrauded the government or have

accepted bribe payments from contractors in exchange for awarding contracts or taking other

official action on beha lf of the Army.

II. INTRODUCTION

2. Special Agents with Army CTD, the Defense Criminal Investigative Service

("DCIS"); the Department of Homeland Security ("OHS"), Immigration and Customs Enforcement

("ICE"); the Federal Bureau of Investigation ("FBI") ; the Internal Revenue Service, Criminal

Investigati ons Division ("IRS"); and the Special Inspec tor Genera l for Iraqi Reconstruction

C"SIGlR"), in conj unction with the United States Department of Justice, Antitrust and Criminal

Divisions ("DOl'') are conducting no investigation into U.S. military employees who participated in

the rigg ing of DoD contracts in Kuwait and Iraq in return for U.S. and Kuwai ti companies paying

these officials bribes during their deployment to Iraq and Ku wait and thereafter. As described more

fully below,I have probable cause to believe tha t John Cockerham ("J.COCKERHAM'), a Major in

the United States Army, accepted cash from contractors in Kuwait in return for awarding contracts to

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them and that J. C()CKERHAM, his wi ft:Melissa Cockerham ("M. COCKERl -lAM"), alit

aundered millions of dollars in illegal bribe proceeds that J .

COCKERHAM was given, resu lt ing in violations of 18 U.S .C. § 20 1 (bribery), 18 U .S.C. § 37]

(fraud against the United Sta tes and conspiracy); and J8 U.S.C. § 1956(h) (mon ey laundering

consp iracy) . I also have probable ca use to believe tha t fruits, instrum entalities, and evidence of this

conduct will be located at 55'1 Graham Road , Fort Sam Houston, San Antonio, Texas, 78234 (the

"SUBJECT PROPERTY").

3. T he information co ntained in this affidav it is based on my personal knowledge and

observation s accumulated during the course of th is investigation; on information I obtained during

interviews; on information conveyed to me by othe r law enforcement personnel; on my review of

documents and interview reports; and on phys ical evidence. The affidavi t is submitted for the

Ii.mited purpose of estab lishing probable caus e in support of this application for arres t and search

warrants, and thus, it does not contain every fact known by me or th c United States.

Ill. j>ACKGROUND

4. J. COCKERHAM was commissioned into the United States Army in 1993; his

current militaly rank. is Major. J. COCKERHAM has held various acquisition and contracting

positions and comp leted numerous military ass ignments and formal co urses specializing in the

fie ld of govermuent procurement and acquisition. In or about 2004. J. COCKERHAM received

an advance d degree in procurement and acquisi tion m anagement. At var ious times between

November 2000 and D ecember 2005, J. CO CKERHA M served in numerous acqu isition and

procu rement positions in Kuwai t, including as a contracting officer with a $ 10 million warrant.

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Kuwait. The A CA was later transferre d to Camp Ari 'ljan and, as a result, J. COCKERHAM was

transferred back to Camp Arifjan until he left Kuw ait. Camp Ariljan and Camp Doha arc both

located jus t outside of Kuwai t C ity, Kuwait

7. On or about December 20,2005, J. COCKERHAM returned to the United States

and was stationed at Fort Sam H ouston, ACA (US Army South), where he worked asa

contracting officer. From August 2006 unlit December 2006, J. COCKERHAM was on a

temporary duty assignment to the Naval Military Base at Guantenamo Bay, Cuba. As of

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Decem ber 2006, however, J. <..:OCKbRllAM returned to Fort Sam Houston and is currently

residi ng with his w ife at the SUBJECT PROPERTY .

8. In December 2006, inc iden t to the se arch of their previ ous res idence, agents

interviewed M. COCKElUlAM..and J. COCKERHAM . During ber interv iew by federal agents,

M _COCKERHAM admitted that she received over $ J mill ion on behalf of J. COCKERHAM

and placed the money in safe deposit boxes in Kuwait and Duhai. During a separate interview by

federal agents. J. COCK1UUlAM admitt ed that he arranged for M. COCKERHAM to receive

this money es bribe pa yments from military contractors ill exchange for mili tary contracts.

During the search of the residen ce, however, federal agents uncovered evidence, including

finan cial records and other documents, that I . COCKERHAM, in fact, received significantly

more money in bri be payments from many more contr actors tha n he admitted in December 2006.

T his evidence indicated that in addition to M. CO CK ERHAM, money was received 0 11 J.

COCKE RHAM', bebalfb Person A, all employee of one mil itary

co ntractor, and Person B, a person al friend of J. COCKEIU-IAM's.

IV . PRO BABLE CAUSE THAT J. COCllli!U{AM. M. CO CKERHAM. and__CQMM!TIEO A CRIME

9. On December 21,2006 , federal agents from Army eID and DClS executed a

federal search warrant on the CO CKE RHAM 's previous residence at 550 Graham Ro ad. During

the search, various fin ancial documents , address hooks, communications. ledgers, and corporate

do cuments were se ized as evidenc e. On the day of the search, and the following day. I.

COCKERH AM gave voluntary statem ents to federal agents, wherein be admi tted (hat hiSwife,

M. COCKEIUlAM, received money from two contractors' representatives 01] his behalf end that

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M. COCKE RHAM placed this mon ey in safe deposit box es. 1. COCKF.RHA.J\.1 admitted that the

money came from contracto rs who had contracts with the DoD managed by 1. COC K.URHAM.

J, COCKERl-l AM also admitted th at he knew <I t the time he received the money that lt W3::;

wrong to accept money from mil itary con tractors .

10. During tbe search, agents discovered and se ized a handwritten ledger believed (0

have been c reated by J. COCKERHAM. The ledger detailed m oney J. COCKERHAM received

and the money he anticipated receiving from various contractors. For each separate payment, the

ledger liste d the amount, th e source of the payment, and who rece ived it on 1. COCKERllAM's

behalf. Accord ing to the ledger, M. COCKERHAM received $2 ,1 million from four contractors,

in tot al, the

ledger records that J. COCKE RHAM received $9.6 million in bribe payments from at least eight

contractors and anticipated receiving $5.4 million more. The ledger listed six associates of 1.

COCKERHAM's, including M. COCKERHAM'-erson A, and Person B, Who

received money on his behal f. Information conta ined in the ledger bas been corroborated by

witn ess statements, finan cial docu ments, and other records uncovered in the Decel11b~r'200~ . .v ,

search.

11. According to 1. COCKERHAM' s ledger, two bribe payers used the same

associate, Person A. to convey m onies to J. COCKERHAM totaling $ 1 million. During the

search of J. COCKERHAM's home, agents discovered a receipt from the Jordan Natio nal Bank,

Jab l al-Hu ssein Branch, documenting a May 23, 20 05, deposit of $240,000 in U.S. hundred

dollar bilts int o a safe deposit box in the name of Persou A. In addition, a bank account

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containing approx imately $1"'5,000 at the Bank of America in the name of Person A was seized

hy tbe United States 01'\ or about February lO, 2007 . J. COCKER HAM's ledger documented that

two bribe payers used another J. COCKERHAM associate, Person B, to convey $1.5 million to J.

COCKERHAM.

12. A review of J. COCKEllliAM 's contracting work for ACA in Kuwait confirmed

that he, in fact, directly awarded and took part in the award of cont racts to those contractors from

whom the ledger indicated he received brib e payments .

13. Duri ng her interview by federal agents in December 2006 , M. COCKERHAM

admitted that she traveled to Kuwai t to visi t her husband all two occasions. While in Kuwait

during the firs t trip, which M. COCKERHAM placed in approximately 2004, J. COCKERHAM

called M. COCKERHAM and told her that an individual was going [0 pick her up at her hotel in

Kuwait so that she could open a bank account and a safe deposit box. Shortly thereafter, that

individual arrived at M. COCKERHAM's hotel and took her to the Commercial Bank ofKuwait,

where M. COCKERHAM opened a bank account end a safe deposit box. According to M.

COCKERHAM, that individual picked M. COCKERHAM up at her ho tel the following day and

gav e her a bag containing approximately $800,000 in Kuwaiti and U.S. currency. He then took

her to the Commercial Bank of Kuwait where she placed the money into the safe deposit box.

14. In his interview by federal agents, J. COCKERHAM confi rmed. tha t he arranged

for thi s individual, a representative of a mil itary contractor to whom J. COCKERHAM awarded

contracts, to give. U.S. and fore ign currency Lo M. COCKERHAM. 1. COCKERlIAl\:1 stated that

he believed that the money tota led $800,000 and that the cash remained in a safe deposi t box in

Dubai. J. COCKERHAM 's ledger liste d M, COCKERHAM as hav ing received $300,000 from

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this indi vidual ; list ed $9UO ,000 as having been re ceive d ill total by M . COCKERIlAM_

and Person A on J. COCKERHAM 's behalf; and noted that J. COCKERHAM anticipated

receivin g $300,000 more .

15. In her interview in December 2006, M. COCKERHAMstated that she, her

children, and her sister visited J. COCKERHAM i» Kuwait ou another occasion in 2005 . During

this trip, M ,COCKER.HAM left the children with her sister in Kuwait and traveled to Duba i with

a woman to whom she was introduced by J. COCKERllAM. According to M. COCKERHAM,

this woman assisted M. COCKERHAM in starting a business in Dubai, "Worldwide Trading."

While III Dubai, M. COCKERHAM stated that this woman gave M . COCKERlIAM a retail -type

bag that contained approximately $500,000 in Etnirati and United States currency and took M ,

COCKE1UlAM to a bank in Dubai where M.. COCKERHAM opened a safe deposit box and

deposited the money. M . COCKERHAM explained that J, COCKERHAM made the

arrangements for her meetings with these ind ividuals and staled that she did not want to ask her

husband ' (too many questions."

16. J. COCKERHAM acknowledged in his interview that tile woman who

accompanied M. COCKERHAM to Dubai represented a U.S. government contractor, and that he

believed she was the sister of the president of this company. 1. COCKERHAM stated that this

woman made two cash payments, in U.S . and Kuwaiti currency, to M . COCKERHAM, totaling

app roximately $300,000. J. COCKERHAM recalled that M. COCKERHAM placed the money

in a safe deposit box in Kuwait. J. COCKERHAM nduutted that he understood this U.S.

government contrac tor expected to receive govermnent contracts in return for the money

provided to M. COCKERHAM on J. COCKERHAM's behalf

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17. J. COCKRRHAM'~ ledger partially corroborates his an d M . COCKERJiAM':-;

statements regarding this trip by M . COCKERHAM La Dubai . According to the ledger, J.

COCKERHA M rec eived from this U. S. gove rnment contractor money total ing $ ].7 mill ion, SI

milli on ofwhi ch was received thro ugh M . COCKERH AM . Du ring his interview in December

2006, J. COCI<.llRHAM ad mitted that this U.S. government contrac tor performed work on

acq uisi tions .that he managed while he was stationed in Kuwait.

18. During the December 2006 search, agents found three pages cf h andwritten notes

regardin g the receipt and transfer of money, in handwriting believed to be M. COCKERH AM's.

One page contained notes about a United Arab Emirates address with notations : "US dollars,

dirhams, accounts" and "safe deposit box. " Tbe note also stated, "6,000 dirhams," "5,000 US

dolla rs," "less $19,000" followed by tbe notation , "deposited September 8,2005:' A second

page of notes indicated that $500,000, packaged in separately identified packages, was

transported by M. CO CKERHAM on or about September 10,2005, as follows:

SUS 200.000 yellow DHL bag

200 ,000 # 1 bag purple + white

100,000 leltg[sie] wh ite color

Di rhans 1,000,000 2 white bags esse blue

5000 + 50 ,000 - $55,000 SUS carried w/me

The third page of no tes, dated September la, 2005, indicated steps M . COCKERHAM took to

open an account with the Abu Dhabi Commercial Bank ("ADCS '') and ob tain a safe deposit box

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at Union National Bank. Th is page also lias a note with the address 10r " Worldwide Intemutioual

Trading Co. " The dates on these pages correspond with dates during which M. COCKERHAM

traveled to the Mi ddle F~'\SL

19. During her interview in Dec ember 2006, M. COCKERHAM sta led tha t in August

2006, she travel ed to Dubai to attend to her business, Worldwide Trad ing. She abo stated that

she pa id the fee for fin addit iona l year to mainlain the safe deposit box she had opened in 2005.

Oil or about D ecember 2 1,2006, M . COC KF.RI lAM vo luntarily prov ided agents with the keys

she identified as belonging to the sefe deposit boxes in Kuwait and Dubai.

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25, During the'n ecember 2006 search of J. COCKERHAM's previous residence,

agen ts seized numerous documents related to the laundering of l1lont y. For example, documents

found during the searcb related to the establishment of offshore bank accounts, induding:

•multiple pages comparing the benefits of various offsh ore banking havens; account application

documents from the First Caribbean International Bank (C ayrrtan) in the name of John

Cockerham; a letter from First C aribbean dated June 14, 2005, mem orializing a visit by PerSOD

B; account open ing infcnuation from Butterfield Bank, Grand Cayman; account opening

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1, confinnaticn dOCUUlClllS ill the name ofM. CQCKErulAM at Firs t Curacao International Bank.

• N.V.j fifteen pages of lntcrnct research into the advantages of offshore accounts in Barbados;

four pages on the anti -money laundering statutes enacted by the Caym an Islands; and inform ation

about several cqmpaniea' commercial products aimed at safeguarding offshore assets. including

"Bulletproof Asset Protection," an d the Bqulry Devel opme nt Group. Agents also sdiud a,•handwrit ten note reflecting J. COCKERHAM'!: interes t in two books: "Crime and Secrecy: 1'he

USf of Offshore Ranks and Companies," and "Offshore IIaven Banks , Trusts, and Companies :

The Business of Crime in the Euromarket" by Richard Blum. A second handwri tten page

contained notes on how to purchase pro perty through a Iriend in order to protect (he identi ty of

the true owner.,..

V. l' ROBABLB CAUSE TlIAT EVlDliNCB IS LOCATED AI THErREMlSES"!'O BESEARCHER

\ "

26. The SUBJECT PROPERTY, 554 Gmbam Road, Fort Sam Houston, San Antonio,

Texas . 78234 , is J. COCKERHAM ' s and M. COCKEIUlAM's residential address. Federal agents

confirmed through the Fort Sam Houston housing office that1. COCKERHAM and M.

COCKERl-lAM currently reside at the address . Based upon my training, experience, and

participation in tbis invest igation , and based upon admissions by J. COCKERHAMduringhis

December 2006 statement, I believe that evidence of vioJations of 18 U.S .C. § 201 (bribery), J8

U.S.C. § 371 (fraud against the United States and conspiracy); and 18 U.S.C. § J956(b) (money

laundering conspiracy) willbe found at the SUBJE CT PROPERTY.

27. From on or about April 20, 2004, until on or about June 26,2007, J. COCKERHAM

and M. COCKERHAM res ided two doors down Graham Road{rom the SUBJECT PROPERTY at

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SSO Graham Road, 1'"011 Sam IIOl1 !.' tOll, San Autouio, Texas . Federa l agen ts searched this previous

resid ence on or about December 21, 200 6. Their previou s residence if; currently undergoing

renovations and has been emptied of their household goods. On or about June 26, 200." J.

COCKEIU-IAM and M. COCKI3R1-fAM moved, along wi th their household goods , to the SUBJECT

PROPERTY, a newly renovated unit at Fort Sam Houston. Based on iny experience, I believe J.

COC KElU-lAM. and M. COCKEIU:l.AM an: likely to have moved all of their household goods and

po ssessions to the SUBJECT PROPERTY when they moved in or around June 200 7.

28. Based on the voluminous information on offs hore bunk accounts, money laundering,

and asset protection services found in their residence in December 2006, it is likely that subsequent

to the December 2006 search, J. COCKERHAM and M . COCKERHAM continued to arrange for the

concealment of bribe proceeds . Addi tion al records concerning these top ics as we ll us records of

additional financial transactions may be maintained within the SUBJEl."'TPROPERTY. Based upon

my training, experience, end participation in this and similar investigations, I believe that J.

COCKERH AM may also have m ade arran gements for brib e proceeds, in the form of cash or

otherw ise, to be mailed, converted, orotherwisemade acr.;ess ihleto him at his previous residence , at

the SUB JECT PROPERTY, or elsewhere, and records of such mailings or transactions are likely to

be found at (he SUB JECT PROPERTY.

29. Bas ed upon my training, experience find participation in other finan cial investigations

invo lving large amounts of fund s derived from criminal activity, and based upon conversations with

members of the law enforcement community who have also inves tigated su ch crimes, I know that

criminals often attempt to legitimize or "launder" the proceeds of their criminal act ivity. T o

accomplish this goal, crimina ls us e domestic and foreign banks and their at tendant services,

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securi ties, cashiers ' checks, safe deposit boxes, real estate, sbell corporations, and business fronts.

Records of such corporations and fro nts identified during the search of l . COCKERHAM's previous

residence, such as D & } Trading, Abdu llah American 'I'ra diug, Worldwide International Trading ,

and Triad United are likely [ 0 be fou nd at the SU BJECT PRO PERTY . In addition, evidence of thei r

attempts to legitimize or " launder" the proceeds. such as batik records, brokerage accounts,

secu rities , and other similar types of reco rds . is commonly secre ted at their residences. Based on my

experience, I believe evidence of this typc may be found at the SUBJECT PROPERTY, Including

current statements of accoun ts that J. COCKERHAM or M. COCKJJRHAM may hold at ADCB , the

Commercial Bank of Kuwait, the Ne therlands Bank, the Sl1arjah Islamic Bank, and the Union

National Bank in Dubai .

30. Bas ed on property records. including those of a parcel ill downtown San Antonio

purchased in or about 2006 and handwritten notes suggesting methods to launder money through the

purchase of real property wh ich were recovered from the search of the prev ious residence, 1 believe it

is likely that records of such real property, including ins urance payment.'>, mortgage payments, and

c los ing documents may be contained within the SUBJECT PROPERTY .

31. Based on my tra ining and experience as well as the telephone numbers of contractors

from whom 1. COCKERHAM receiv ed bribe money found at his previous residence, 1 believ e it is

likely that J. COCKERHAM made telephone calls to conspirators after the search of h is previous

residen ce in December 2006, records of which are likely to be found at the SUBJECf PROPERTY.

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VI ~'ONCLU.sl@

2H3226 4123 TQ:2e23530819 P.24

32 . I bel ieve that there is probable cause that J. COCKEIU IAM has committed bribery

and tha t J. COCKERHAM, M. COCKF.RHA~aVe committed conspiracy and money

laundering conspiracy, end that the evidence, contraband, fill its and inst rumentalities, and property.

designed and intend ed to be used to commit the violations listed herein. arc present at 554 Graham

Road. Fort Sam Houston, Texas, 78234. as described in Attachment A, including the items listed in

Attacbmeat B. Accordingly, l respectfu lly req uest warrants to arrest J. COCKERH AM, M.

COCK..ERHA~1d a warran t to search tbc premises described in Attachment A

(Premises to Be Searched) an d to seize tbe items described io Attachm ent B (Items To De Seized).

SWORN TO AND SUllSCRlBED BEFORE ME THIS 21st DAY Of JULY, 2007 .

Hon rablc Pamela MathyUni ted States Magistrate JudgeSan Antonio, Texas

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Attachment A - Premises to Be Searc hed

554 Graham Road, Fort Sam Houston, Texas 71':234. This location is <I two-story single­family residential dwel ling 1)1' standard commercial construction located on the cast sideof the 500 blo ck of Graham Road, between Schofie ld Road (south) and Harney Road(north). The residence is identified by the numbers "554 " atta che d on the lower rightexteri or ncar the entrance. The exterior of thc house appears to be constructed ofwhilestucco with reddish cement roo fing tile. The primary en trance is located on the west faceof the house and a rear entrance IS located on the east face of the house.

There is a detached garage of sa me construction on the east end of the residence, believedto be shared with all adjacent neighbor (552 Graham). The garage can be accessed froma roll-up entrance door located all the east face of th e bui lding, with entrance from aneast-end paved alley way; and an entrance door located on the west end of the garage.There is a lock on the roll -up door of the garage.

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8. Telephone: calling cards .

As used above In paragrupba 1-8, the terms records, documents, programs,

documentation, applications, or materials includes records, documents, program s,

applications, or materials created, modified, or stored ill .any form, including any optical ,

electrical, electron ic, or magnetic form (such as any information en aD optical, electrical,

electronic, or magnetic storage device), including floppy disks , hard disks, 7.IP disks,

CD ·ROMs. optical disks, backup tapes, printer buffers or other device memory buffers.

smart cards , memory calculators, pagers, cellular telephones. personal digital assis tants

such as Palm Pil ots hand-held computers, e-mail servers, as well as opened and unopened

email messages and My printouts or readouts from any optical, electrical, electronic, or

magnetic storage device; any handmade form (such as writing, draw ing, or painting); any

mechanical form (such as printing or typing); any pho tographic form (such as microfilm,

microfiche, prints, slides, negati ves, videotapes, motion pictures, or photocopies); or any

voice form (including answering machine tapes and opened end unopened voicernail

messages).

9. Items relating to computers, including:

a . images of compu ters;

b. computers, storage devices and related equip ment capable of being

used to commi t, further or sto re evidence of the offenses listed above, includin g programs

and data on those computers or devices;

c. computer equipment used to facili tate the transmission , creation,

disp lay, encoding or storage of data, Includ ing word processing equipment, modems,

docking stations, monitors. CD burners, printers, plotters, encryption devices and