This is just for the deets. Don't doxx people.

Defendants DAD and MOM, a married couple (together, “the FAMILY”), live in CITY, STATE. DAD is president of a real estate development firm in CITY, STATE. As set forth below, the FAMILYS took part in both the college recruitment scheme and the college entrance exam cheating scheme. RINGLEADER has advised law enforcement agents that in or about 2015 and 2016, the FAMILYS agreed with him to use bribery to secure their older daughter’s admission to college as a recruited athlete. Initially, according to RINGLEADER, he sought to secure the FAMILYS’ daughter’s admission to USC—her first-choice school¹—as a purported soccer recruit. In or about mid-September 2015, RINGLEADER e-mailed her high school transcripts, ACT score and a falsified soccer profile to Janke, who forwarded the materials to the USC women’s soccer coach.

On or about February 17, 2016, an assistant athletic director at USC e-mailed the women’s soccer coach that the application had been diverted to the regular admissions process due to a “clerical error.” On or about May 20, 2016, Ali Khosroshahin, the former head coach of women’s soccer at USC, forwarded the falsified soccer profile, ACT score and transcripts on RINGLEADER’s behalf to Jorge Salcedo, the head coach of UCLA men’s soccer Khosroshahin wrote: “soccer player/student manager. I have attached her profile, player explanation, transcripts for both high schools and ACT scores…will make sure she has registered with the NCAA. Please let me know if you need any additional information[.]” On or about June 28, 2016, the UCLA student-athlete admissions committee approved the FAMILYS’ daughter for provisional admission that fall. RINGLEADER notified the FAMILYS via e-mail the following day. MOM responded, copying DAD and their daughter²: "I know it has been a rough ride but I thank you from the bottom of my heart and soul for your persistence, creativity and commitment towards helping [our daughter]."

On or about July 7, 2016, RINGLEADER directed a payment of $100,000 from one of the FAKE CHARITY charitable accounts to a sports marketing company controlled by Salcedo. RINGLEADER subsequently also caused FAKE CHARITY to issue a check to Khosroshahin in the amount of $25,000. On or about July 8, 2016, Masera sent MOM an invoice from FAKE CHARITY in the amount of $250,000. The invoice stated: “Private Contribution – Letter of receipt will be provided upon payment.”

On or about July 11, 2016, DAD e-mailed RINGLEADER, copying MOM: “Thanks for the follow up call regarding the attached Key Worldwide Foundation invoice. Per our discussion can you please send me an email confirming that if [our daughter] is not admitted to UCLA as a freshman for the Fall 2016 class that The Key Worldwide Foundation will refund our $250,000.00 gift. Again, both MOM and I are greatly appreciative of all your efforts on [our daughter]’s behalf!” That same day, RINGLEADER e-mailed the FAMILYS: “[T]his is to confirm that your donation of $250,000 to The Key Worldwide Foundation supporting educational initiatives we have created to help those who need it the most will be returned if [your daughter’s] admission to UCLA is reversed from the email acceptance she has already received.” On or about July 15, 2016, FAMILY transferred 2,150 shares of Facebook, Inc. stock, having a value of approximately $251,249, to FAKE CHARITY. Approximately one week later, Masera sent the FAMILYS a letter acknowledging the purported charitable contribution, and stating: “Your generosity will allow us to move forward with our plans to provide educational and self-enrichment programs to disadvantaged youth.” The letter falsely indicated that “no goods or services were exchanged” for the money.

RINGLEADER has advised law enforcement agents that the FAMILYS thereafter agreed with him to engage in the college entrance exam cheating scheme for their younger daughter.³ On or about January 23, 2017, MOM e-mailed RINGLEADER documentation of ACT, Inc.’s approval for her younger daughter to take the ACT over successive days. On or about May 8, 2017, MOM e-mailed RINGLEADER: “She is working towards June 10, 11 testing in LA . .Please send me details of testing location and anything I need to do beforehand.” On or about June 9, 2017, RINGLEADER’S ASSISTANT traveled from Tampa to Los Angeles. The FAMILYS’ daughter took the ACT at the West Hollywood Test Center on or about the following day. RINGLEADER’S ASSISTANT returned to Tampa on or about June 11, 2017. The FAMILYS’ daughter received a score of 31 out of a possible 36⁴ on the exam.

On or about June 12, 2017, RINGLEADER paid RINGLEADER’S ASSISTANT $15,600 via a check issued from one of the FAKE CHARITY charitable accounts. On or about June 21, 2017, DAD caused shares of stock having a value of approximately $101,272 to be transferred to FAKE CHARITY. Thereafter, according to RINGLEADER, the FAMILYS agreed with him to secure their younger daughter’s admission to USC as a purported rowing recruit, even though she was not competitive in rowing, but instead was an avid equestrian. In or about October 2017, RINGLEADER sent the FAMILYS’ daughter’s high school transcript and fraudulently obtained ACT score to Heinel, writing, “Another Crew Girl,” and directed Janke to create a crew profile for her. The profile, which RINGLEADER then forwarded to Heinel, falsely stated that the FAMILYS’ daughter was a “Varsity 8 Stroke” for the Redwood Scullers and listed a number of falsified crew honors. Heinel presented the FAMILYS’ younger daughter to the USC subcommittee for athletic admissions as a purported crew recruit on or about November 30, 2017. On or about December 15, 2017, Heinel e-mailed RINGLEADER a letter notifying the FAMILYS’ daughter that she had been conditionally admitted to USC as a student athlete. The letter stated: “Your records indicate that you have the potential to make a significant contribution to the intercollegiate athletic program as well as to the academic life of the university.” RINGLEADER forwarded the letter to the FAMILYS and their daughter, writing, “Please keep this hush hush till late March.” MOM responded, “Very exciting news…we will definitely lay low until March . . . Would you like to chat next week to discuss any steps I need to take on my end for USC? Thank you again for your help!” RINGLEADER replied, “Only steps have been discussed with DAD.”

On or about April 9, 2018, shortly after USC mailed a formal acceptance letter to the FAMILYS’s daughter, a FAKE CHARITY employee e-mailed MOM a $250,000 invoice for the FAMILYS’ “generous donation to The FAKE CHARITY.” MOM responded, copying DAD, “We are out of the country and will send payment early during the week of April 16th.” On or about April 20, 2018, DAD caused shares of stock having a value of $249,420 to be transferred to FAKE CHARITY. RINGLEADER has advised investigators that he earmarked $50,000 of the FAMILYS’ payment for Heinel, who in July 2018 began receiving monthly payments of $20,000 from FAKE CHARITY.

In a call on or about August 23, 2018, RINGLEADER and MOM spoke on the telephone about engaging in the college entrance exam cheating scheme on behalf of the FAMILYS’ third child. The call was intercepted pursuant to a Court-authorized wiretap. In the call, RINGLEADER asked MOM whether they were going to try to “control the test room or is he taking it on his own.” MOM responded that they wanted to control the testing environment.

On or about September 26, 2018, DAD called RINGLEADER and requested a receipt, for tax purposes, for his purported $100,000 contribution to FAKE CHARITY⁵ for his younger daughter’s testing scheme. The following is an excerpt from the call.

DAD Hey, I was checking for one thing, just for my taxes. I need to get the letter, like you did last time—

RINGLEADER Okay.

DAD --for the-- for the Facebook stock that I did—

RINGLEADER Okay.

DAD --do you-- that I think was like 100,000, something like that, las-- is-- can you-- do you track that down to your guys, get the exact amount—

RINGLEADER Yeah.

DAD --internally—

RINGLEADER Yeah. Lemme—

DAD --if you wouldn’tm--?

RINGLEADER --lemme-- lemme find out. Was this for-- was this for [your second daughter]?

DAD This was, when we did the testing. Yeah. Yeah.

RINGLEADER Uh—

DAD I can give you exact date of it, that the stock-- I can actually send that to you, if that helps you. RINGLEADER Okay. Why don’t you do that?

DAD Yeah.

RINGLEADER That would be grea—

DAD Yeah. And, actually got it for-- a copy of it from the broker. But I’ll do that to you. That’d be awesome, just that one-page letter—

RINGLEADER Uh—

DAD --saying it’s a 501--(3)—

RINGLEADER Okay.

On or about October 24, 2018, RINGLEADER called DAD at the direction of law enforcement agents and told him that FAKE CHARITY was being audited by the IRS. The following is an excerpt from the conversation, which was consensually recorded.

RINGLEADER So, so I’m calling because I’m in Boston—

DAD Uh-huh.

RINGLEADER --and I-- so what’s happened is my foundation is, is getting audited now.

DAD Uh-huh.

RINGLEADER Which, as you know, is pretty typical.

DAD Uh-huh.

RINGLEADER Right? So they’re looking at all my payments.

DAD Okay.

RINGLEADER So they asked about your payments. One of them for when [RINGLEADER’S ASSISTANT] took the test for [your second daughter].

DAD Okay.

RINGLEADER The payment that we made to Jorge, to help [your first daughter] get into UCLA through soccer.

DAD Okay.

RINGLEADER And then the payment that we made to Donna Heinel at USC to help [your second daughter] get in through crew.

DAD Okay.

RINGLEADER So, of course I’m not going to tell the IRS this is where the money went—

DAD Right, right, right.

RINGLEADER --and [inaudible]. So I just, I just want to make sure that-- what I’ve told them so far is that that 600K-plus has actually gone to pay for-- paid tour foundation for underserved kids.

DAD Uh-huh.

RINGLEADER So I guess, first-- one of the questions I have is, did you take a write-off for those?

DAD I did take a write-off for those, yes.

RINGLEADER Okay. All right, I just, I just want to make sure I’m—

DAD Yeah.

RINGLEADER --on the same page as you.

DAD Yeah, I did, I did.

RINGLEADER Okay. Okay.

DAD I did. I mean-- go ahead, I’m sorry.

RINGLEADER No, you go.

DAD Yeah, well, I got-- remember, I was asking for the letter [inaudible] asked for, you know, to the extent that we don’t have it. You know, if we do get audited or something, we would need a letter or something like that.

RINGLEADER Gotcha. Totally.

DAD That’s after the fact. Okay.

RINGLEADER Okay, no problem. So I just wanted to make sure our stories are aligned.

DAD Yeah.

On or about December 3, 2018, RINGLEADER called MOM at the direction of law enforcement agents and told her that FAKE CHARITY was being audited by the IRS. The following is an excerpt from the conversation, which was consensually recorded.

RINGLEADER So they asked about the payments that DAD had made. And I-- I think I told him. But I’m going to tell you. Essentially, that I didn’t say anything about [your second daughter] taking the, the test down at [the West Hollywood Test Center] and having [RINGLEADER’S ASSISTANT] and-- [RINGLEADER’S ASSISTANT] take it and Igor being the site coordinator. I didn’t say anything about that. I just said that it was a donation to our foundation for underserved kids. Are you okay with that?

MOM Okay. Yeah. Yeah.

Although the quality of the phone call was clear, MOM then told RINGLEADER, “It’s really hard to hear you but why don’t we talk later tonight[.]” RINGLEADER went to the FAMILYS’ home later that evening to meet with DAD. The meeting was consensually recorded. During the meeting, RINGLEADER asked if MOM—who was traveling—wanted to participate by phone. DAD responded: “You know, I am so paranoid about this fucking thing you were talking about. I don’t like talking about it on the phone, you know.” Later in the meeting, DAD noted: “I’m so paranoid about MOM, I go, ‘I really don’t want you talking on the phone to [RINGLEADER] about this.’ You know, I’m thinkin’, you know, are they—I mean, I can’t imagine they’d go to the trouble of tapping my phone—but would they tap someone like your phones?” DAD and RINGLEADER then discussed what would happen if the FAMILYS received a call from the IRS. The following is an excerpt from the conversation.

DAD [W]orst case, we were to get a call from them, and they would say to you, you know, I guess, “Prove you gave this money,” they’d ask for some—

RINGLEADER Which you did.

DAD --yeah-- ask for some kind of thing, and I don’t-- I only got, I think, a, a, a receipt from you, or, I don’t know, like, one-- like, the last two of ’em I don’t think I did.

RINGLEADER Okay.

DAD If we-- if we-- you know, if you want to—

RINGLEADER Well, we can get that to you.

DAD --i-if we can do that –

RINGLEADER Yeah, absolutely.

DAD --that would be great, yeah. But, you know, just the letter saying “Thank you for your gift” or whatnot, of whatever—

RINGLEADER Right.

DAD --you know, you’re helping out with. But so, so let’s say they, they, they, they, they do that. For example, when we did the testing thing—

RINGLEADER Mm-hmm.

DAD --that was as a gift, right? Yeah.

RINGLEADER Right.

DAD And they’re not-- there’s no way they can correlate and say that that wasn’t for a gift? That would only be if they would talk to you about that and say “Where did that go?” Right? You know what I’m saying?

RINGLEADER Right. Right—

DAD Yeah.

RINGLEADER --so they wouldn’t-- at least, I wouldn’t know—

DAD Right.

RINGLEADER --how they would know?

DAD Yeah.

RINGLEADER It would just be looked at as a gift.

DAD Mm-hmm.

RINGLEADER Um—

DAD But what happens when they track,[RINGLEADER], worst case, that 75,000, and they say, “Show me where that went”?

RINGLEADER Well-- So that-- so I guess what I-- I guess-- that’s a good question.

DAD Yeah.

RINGLEADER So that 75 comes in.

DAD Uh-huh. RINGLEADER It’s a part of a lot of other money, right?

DAD But part—

RINGLEADER So—

DAD --part of-- When you say—

RINGLEADER Well, because a lotta other money’s in, in the pot.

DAD Coming in the pot, right.

RINGLEADER Right? And then I’m turning around and paying [RINGLEADER’S ASSISTANT] and Igor. And so I guess they could s-- they could see that—

DAD Right.

RINGLEADER --and maybe they’ll cor-- Yeah, that’s a good q-- that’s good—

DAD Yeah, yeah.

RINGLEADER --because they may correlate—

DAD Right.

RINGLEADER --that the testing was a part of it.

DAD Ri-- I, I don’t know, yeah.

At a number of points in the meeting, DAD and RINGLEADER discussed the potential repercussions if the IRS were to uncover the true purpose of the payments to FAKE CHARITY:

RINGLEADER And I’m just saying, “Hey, I was just told to call everybody.”

DAD Yeah, no, I appreciate that, and I’m glad you did. It’s just something that when it happened, my stomach, like, kind of fell out.

RINGLEADER Oh, well, sure.

DAD Yeah.

RINGLEADER I think it should.

DAD Oh, yeah. I’m just thinking, oh my God, because you’re thinking, does this roll into something where, you know, if they get into the meat and potatoes, is this gonna be this-- be the front page story with everyone from Kleiner Perkins do whatever, getting these kids into school, and—

RINGLEADER Well, the, the person who’d be on the front page—

DAD Well, I, I-- But if-- but they, they –

RINGLEADER Yes.

DAD --went the meat and potatoes of it, which a-- which a guy would love to have is, it’s so hard for these kids to get into college, and here’s-- look what-- look what’s going on behind the schemes, and then, you know, the, the embarrassment to everyone in the communities. Oh my God, it would just be-- Yeah. Ugh.

Later, in the conversation, DAD told RINGLEADER that if they proceeded with the college entrance exam cheating scheme for their third child, “I think we’ll definitely pay cash this time, and not, not-- not run it through the other way.”

1: The fact her first choice was USC should have been a red flag that she wasn't cut out for UCLA

2: The daughter definitely knew about this.

3: Younger daughter cheated on the ACT

4: And she only got a 31 LMAO

5: Dad drops $100,000 for his daughter to cheat and wants to write it off for a tax deduction. Morally bankrupt as they come

TL;DR

Family pays $250,000 in Facebook stocks for the first daughter to go to USC as a soccer recruit. There was a filing error and her app was sent to the regular decision pool and not the athlete pool where she was sure to be rejected. The USC coach sent her app to Jorge Salcedo at UCLA where he accepted her and was paid $100,000. Family paid $100,000 for second daughter to take the ACT in a controlled environment where she got a 31/36. Then an additional $250,000 in stocks was paid for her to be accepted to USC as a rowing recruit. There were talks of arranging for their son to take the ACT in a controlled environment for an undisclosed cash amount.