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UNITED STATES DISTR& COURT
SO- DISTRICT OF TEXAS
HOUSTON DIVISION
UNITE0 STATES OF AMERlIcA `§ &No. H-03-
9
V.
LEA W. FASTOW . 5 vlolatio~: 18 w.s.c, 65 371
comm.it WK~ Fraud and Defraud
States); 1956(h) (Money
cmlgmq); 2 (Aiding
U&C, 5 7206(I) (Palm Tax
The Grand Jury charges:
1. ii&!&W
I. At all timm r&want TV this Indidnwn~ Enrcm Corp. ("Enron") was an
axporation with its h~dquwm in Houstoq Tens. Among other businesses, Fmmn was
engaged in the purchase and sale of natural gas, coastmtio~ and owumhip of pipelines and
power facilities, provision of tel0amm unhation sewicm, and trading in'contraccp to buy and
-vuioua cmmodities. Before it filed for bmkruptcy on December 2,200 1, Enron was the
seventh 1-t corporation in the Unit4 State% . I
II. mPRmclPALcfmT~mToRs
2. The defendant LEA W, FASTOW, a reaidmt of Houston, Texaq was an Enmn
employ= between May 1991 aad May 1997. She held veriou positions at Enron, incUing
Diiector and As&ant Treasurer of Cmporate Finance. LEA W, FASTOW earned a Masters
* ,
Degree in J3ush~ Admbistraiion id Fin- in August 1987.
SNIPPETS:
Before it filed for bmkruptcy on December 2,200 1, Enron was the
Diiector and As&ant Treasurer of Cmporate Finance.
LEA W, FASTOW earned a Masters
Fastow *orted directly to Enton's Chief
Pastow was married ta defendant LEA W. PASTOW.
Kopper reported to Fastow.
The goats of the scheme included:
wind farms that were more than f&y percent owned by an electrio utility holding company were
reap the proceeds Born the fhma fof thwehrts, without the fatms losing their valuable QF
through a sale to m SPE known as RADR TJI reality, Enron retained an illegal and secret
RADR proceeba, which they &e&d to theimselves, their Sends, and famika.
$5 10,000 that was supposed to cautitute rhe independent 3% equity in IUDR.
Rather than providing the iavastment money
To fizaher distance Fastaw from the transaction, Fastow and the defendant LEA W, FASTOW
reporting to the Internal Revenue Sawice C'IRS").
and the second nominee who were fiienh of the FASTOWS -there WM no plau&le cover story
the break up fe was not interest income from a loan betwam
his duty to provide honest services to Etlroa and its shareholders.
federal iname tax returns.
and fraudulent pretemes, representations and promises, and fbr the purpose of executiag such
in it&mate and foreign cokmrce writ@> &ns, signals, pictures and sounds, ti in violation
Southern District of Texas and ekwhere, the defendant LEA W. FASTOW and her mspirators
(Title 18, United States Code, Seuthz 371 and 3551 a a.)
yeai 1997, which was vetBed by a written deck&ion that it was made under pet&es of perand was
to every material matter, in that the r&urn reported total income in the amaunt of $2,183,850,
true and correct 3s to every material matter, in that the return reponeci total iwome in the
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