|
In
the District Court of Travis County , Texas 147th Judicial District The State of Texas
§ vs.
§ John Dominick
Colyandro,
§ Criminal
Action No. _______________ James Walter Ellis,
&
§ Criminal
Action No. _______________ Thomas Dale
DeLay
§ Criminal
Action No. _______________
Bill of Indictment John Dominick
Colyandro
Trial Court: 331st Re-indictment of Criminal
Action No. D1DC-05-904150 PID #730883/MNI
#1221697/TCDA-SPD
#4403-03
Bail: $ James Walter
Ellis
Trial Court: 331st Re-indictment of Criminal
Action No. D1DC-05-904151 PID #730881/MNI
#1221680/TCDA-SPD
#4403-03
Bail: $ Thomas Dale
DeLay
Trial Court: 331st DA #D1DC-05900725 PID
#
/MNI
#
/TCDA-SPD #4403-03
Bail: $ Criminal Conspiracy Texas Penal Code §
15.02 (State Jail Felonies) In the name and by
authority of the State of Texas : The Grand Jury of the
County of Travis, State of Texas, duly selected, organized, sworn, and
charged as such at the April term, A.D., 2005, of the 147th Judicial District
Court of said county, in said court at said term, upon their oaths do present
that on or about the thirteenth day of September, A.D., 2002, in the County
of Travis and State of Texas, John Dominick Colyandro, James Walter Ellis, and Thomas Dale DeLay, the defendants herein,
with the intent that a felony be committed, did enter into an agreement with
one or more of each other or with a general purpose political committee known
as Texans for a Republican Majority PAC that one or more of them would engage
in conduct that would constitute the offense of knowingly making a political
contribution in violation of Subchapter D of Chapter 253 of the Texas
Election Code, a violation of Sections 253.003 and 253.094 and 253.104 of the
Election Code, in that said contribution was made directly to the Republican
National Committee, a political party, during a period beginning sixty days
before the date of a general election for state and county officers and
continuing through the date of the election, and indirectly to candidates for
the Texas House of Representatives, and that said contribution included a
prohibited political contribution by a corporation; and that John Dominick
Colyandro, and James Walter Ellis, and Texans for a Republican Majority PAC
did perform overt acts in pursuance of the agreement, to wit: John Colyandro
and Texans for a Republican Majority PAC did accept contributions from
corporations, namely Diversified Collection Services, Inc. in the amount of
$50,000, and Sears, Roebuck and Co. in the amount of $25,000, and
Williams Companies, Inc. in the amount of $25,000, and Cornell Companies,
Inc. in the amount of $10,000, and Bacardi U.S.A., Inc. in the amount of
$20,000, and Questerra Corporation in the amount of $25,000; and James Ellis
and Texans for a Republican Majority PAC did tender, deliver, and cause to be
tendered and delivered to the Republican National Committee and Terry Nelson,
a representative of the Republican National Committee, a check (a copy of
which is hereinafter reproduced) payable to RNSEC (the Republican National State
Elections Committee, a nonfederal component of the Republican National
Committee) in the amount of $190,000, said check being from the same bank
account into which the above-described corporate contributions had been
deposited; and James Ellis and Texans for a Republican Majority PAC did
provide the said Terry Nelson with a document that contained the names of
candidates for the Texas House of Representatives and amounts to be
contributed to each of the said candidates, namely, Todd Baxter, Dwayne Bohac,
Glenda Dawson, Dan Flynn, Rick Green, Jack Stick, and Larry Taylor; and James
Ellis and Texans for a Republican Majority PAC requested, solicited, and
proposed that the Republican National Committee and the Republican National
State Elections Committee make political contributions to said candidates
after the aforesaid check was delivered to Terry Nelson; and John Colyandro
did sign the aforesaid check; and John Colyandro did deliver the aforesaid
check, and did cause the aforesaid check to be delivered to James Ellis by
instructing Russell Anderson to send the aforesaid check to James Ellis; [Indictment Exhibit]
The Grand Jury further
presents that, with the advice and consent of counsel, the defendant, Thomas
Dale DeLay, did heretofore knowingly, intelligently, and voluntarily waive
the application of Articles 12.01 and 12.03 of the Texas Code of Criminal
Procedure to the indictment presented herein. In particular, the Grand
Jury present that with the advice and consent of counsel, the defendant,
Thomas Dale DeLay, did knowingly, intelligently, and voluntarily waive the
requirement that an indictment for the felony offense of criminal conspiracy,
the object of which is a felony other than those listed in Subdivisions (1) through
(5) of Article 12.01 of the Texas Code of Criminal Procedure, may be
presented within three years from the date of the commission of the offense,
and not afterward, insofar as such requirement pertains to the indictment
presented herein, The Grand Jury further
presents that on or about the thirteenth day of September, A.D., 2005, the
Grand Jury of the County of Travis, State of Texas, duly selected, organized,
sworn, and charged as such at the April term, A.D., 2005, of the 147th
Judicial District Court of said county, in said court at said term, upon
their oaths did present an indictment charging the defendants, John Dominick
Colyandro and James Walter Ellis, with the offense hereinbefore charged in
this indictment, and the said indictment was pending in the 331st Judicial
District Court of Travis County, Texas at the time of the presentment of this
indictment. against the peace and
dignity of the State. ____________________________
Foreperson of the Grand
Jury |
|||
|
The State of Texas vs.
John Dominick Colyandro, James Walter Ellis, & Thomas Dale DeLay/Page 1 of
4