Eduardo De La Garza Indicted by Federal Grand Jury
INDICTMENT
COUNTS ONE through THREE: 18 U.S.C. § 666(a)(2), Paying a Bribe to an Agent of an Organization Receiving Federal Funds;
THE GRAND JURY CHARGES:
At All Times Material To This Indictment:
1. EDUARDO DE LA GARZA operated a construction company in Maverick County, Texas called Rio Bravo Construction.
2. Maverick County’s arrangement with contractors who provided labor was that the contractor would receive an initial payment, often times up to fifty percent of the project’s cost, to commence work. When the project was complete the contractor would submit an invoice indicating the project was finished and then the remainder of the funds would be paid.
3. On May 5, 2011, EDUARDO DE LA GARZA, doing business as Rio Bravo Construction, submitted a proposal to Maverick County to construct a concrete pad at the intersection of Windsor Avenue and Bianca Road in Precinct 4 of Maverick County, Texas, The proposal requested $19,800 to complete the work, with a 50 percent deposit ($9,900) required to commence.
4. On May 6, 2011, EDUARDO DE LA GARZA, doing business as Rio Bravo Construction, submitted an invoice requesting the remaining balance of $9,900 for the construction of the concrete slab.
5. On May 31, 2011, the Maverick County Commissioner’s Court unanimously passed a motion to hire Rio Bravo to construct a concrete slab at Windsor and Bianca in Precinct 4 of Maverick County and to pay $19,800 for the work.
6. On June 3, 2011, Maverick County issued check number 000996 to Rio Bravo Construction for $12,150. The check included $9,900 as a 50 percent deposit for the Windsor and Bianca concrete slab, as well as a 50 percent deposit of $2,250 for an unrelated project
7. On June 3, 2011, EDUARDO DE LA GARZA deposited check number 000996 for $12,150.
8. On June 28, 2011, Maverick County issued check number 001010 to Rio Bravo Construction for $12,150. The $12,150 included $9,900 for completing the concrete slab at Windsor and Bianca, as well as $2,250 for completing an unrelated project.
9. On June 30, 2011, EDUARDO DE LA GARZA deposited check number 001010 for $12,150 into his bank account at IBC Bank.
10. As of December 3, 2012, no concrete slab was constructed at the intersection of Windsor and Bianca in Maverick County, Texas.
11. EDUARDO DE LA GARZA in fact made a cash payment to MAVERICK COUNTY EMPLOYEE, who was working in the Maverick County Auditor’s Office, when he received the checks. Both checks were issued without undergoing the appropriate internal review process by Maverick County and payment was made in return for EDUARDO DE LA GARZA receiving the checks.
12. In connection with other construction contracts in 2010 and 2011, EDUARDO DE LA GARZA paid thousands of dollars on multiple occasions to COUNTY COMMISSIONER in return for receiving Maverick County construction contracts.
COUNT ONE
[18 U.S.C. § 666(a)(2)]
13. Paragraphs One through Twelve above are realleged and incorporated by reference as if fully set forth herein.
14. At all times material to this indictment Maverick County, Texas was a local government that received in the one year period beginning on January 1, 2011 benefits in excess of $10,000 under Department of Homeland Security Grant Program Operation Stonegarden.
15. Between on or about May 5, 2011 and on or about June 30, 2011 in the Western District of Texas, the Defendant,
EDUARDO DE LA GARZA, a/k/a Lalo,
did corruptly give, offer, and agree to give a thing of value to MAVERICK COUNTY EMPLOYEE, who was an agent or employee of Maverick County, intending to influence and reward MAVERICK COUNTY EMPLOYEE in connection with a transaction and series of transactions of Maverick County involving $5,000 or more, in violation of 18 U.S.C. § 666(a)(2).
COUNT TWO
[18 U.S.C. § 666(a)(2)]
16. Paragraphs One through Twelve above are realleged and incorporated by reference as if fully set forth herein.
17. At all times material to this indictment Maverick County, Texas was a local government that received in the one year period beginning on January 1, 2010 benefits in excess of $10,000 under Department of Homeland Security Grant Program Operation Stonegarden.
18. Between on or about January 1, 2010 and on or about November 30, 2010 in the Western District of Texas, the Defendant,
EDUARDO DE LA GARZA, a/k/a Lalo,
did corruptly give, offer, and agree to give a thing of value to COUNTY COMMISSIONER, who was an agent or employee of Maverick County, intending to influence and reward COUNTY COMMISSIONER in connection with a transaction and series of transactions of Maverick County involving $5,000 or more, in violation of 18 U.S.C. § 666(a)(2).
COUNT THREE
[18 U.S.C. § 666(a)(2)]
19. Paragraphs One through Twelve above are realleged and incorporated by reference as if fully set forth herein.
20. At all times material to this indictment Maverick County, Texas was a local government that received in the one year period beginning on January 1, 2011 benefits in excess of $10,000 under Department of Homeland Security Grant Program Operation Stonegarden.
21. Between on or about January 1, 2011 and on or about May 31, 2011 in the Western District of Texas, the Defendant,
EDUARDO DE LA GARZA, a/k/a Lalo,
did corruptly give, offer, and agree to give a thing of value to COUNTY COMMISSIONER, who was an agent or employee of Maverick County, intending to influence and reward COUNTY COMMISSIONER in connection with a transaction and series of transactions of Maverick County involving $5,000 or more, in violation of 18 U.S.C. § 666(a)(2).
