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I believe that there is probable cause to believe that Congressman Randall H. Cunningham, aka Duke, aka Duke Cunningham, aka the Dukester, Mitchell Wade, Brent Wilkes, Joel Combs, Thomas Theodore Kontogiannis, aka Tommy K, MZM, Inc., John Michael, ADCS, Inc., 1523 New Hampshire, LLC, Coastal Capital doing business as Home Capital Assurance; The Mortgage Shop ("Coastal Capital"), Parkview Financial, Inc., Axxion Mortgage Corp., and other individuals and entities have violated the following federal laws, among others: (1) Bribery in violation of Title 18, United States Code, Section 201; (2) Making False Claims in violation of Title 18, United States Code, Section 287; (3) Making False Statements or Concealing Facts in violation of Title 18, United States Code, Section 1001; (4) Mail Fraud in violation of Tide 18, United States Code, Section 1341; (5) Wire Fraud in violation of Title 18, United States Code, Section 1343; (6) Honest Services Fraud in violation of Title 18, United States Code, Section 1346; (7) Money Laundering in violation of Title 18, United States Code, Sections 1956 and 1957; (8) Tax Evasion in violation of Title 26, United States Code, Section 7201; and (9) Conspiracy to commit the above listed offenses in violation of Title 18, United States Code, Section 371.
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B. MITCHELL J. WADE 12. According to information provided by Mitchell Wade, after graduating college, he was hired (in approximately 1984) as a civilian employee at the DoD. While employed at the DoD, Wade was actively involved in command and control projects, including ones relating to the counter-narcotics programs. He worked very closely with the Drug Enforcement Administration ("DEA") on these projects and was actively involved in human intelligence 13. Upon leaving the DoD, in 1993, Wade opened MZM, Inc.
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DoD records reveal that a short time prior to October 18, 2002, the Defense Information Systems Agency ('BISA") awardedMZM a blanket purchase agreement ("BPA") under contract number DCA200-02-A-50 16. This BPA provides a contracting mechanism that allows various DoD (and other federal agencies) to purchase from MZM a wide array of program and project management support and services related to diverse fields, including homeland security and law enforcement
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During the 2003 fiscal year (October 2002 thru September 2003), MZM's fortunes changed radically. That year the company received 20 separate task orders, totaling $38,606,063. In 2004, this trend continued, and MZM received 56 separate tasks orders, totaling $65,330,205.
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