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Speight. Plea Agreement Hearing set for 11/16/2023 at 11:30 AM in Richmond Courtroom 6100 before District Judge M. Hannah Lauck. (jsau, )","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/369172297/","id":369172297,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67921622/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/376527359/","id":376527359,"tags":[],"absolute_url":"/docket/67921622/3/united-states-v-sullivan/","date_created":"2023-10-27T11:16:01.642172-07:00","date_modified":"2023-10-27T11:16:01.646322-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"3","attachment_number":null,"pacer_doc_id":"189012991531","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""}],"date_created":"2023-10-27T11:16:01.633270-07:00","date_modified":"2023-10-27T11:16:01.635665-07:00","date_filed":"2023-10-26","time_filed":null,"entry_number":3,"recap_sequence_number":"2023-10-26.001","pacer_sequence_number":10,"description":"Summons Issued in case as to Roxanne Sullivan. (Provided to USMS along with accompanying documents.) (Kat) (Entered: 10/26/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/369172296/","id":369172296,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/67921622/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/376527358/","id":376527358,"tags":[],"absolute_url":"/docket/67921622/1/united-states-v-sullivan/","date_created":"2023-10-27T11:16:01.621533-07:00","date_modified":"2023-10-31T02:29:07.254813-07:00","sha1":"cd46d2c698586c7ddbfd2ee1d9d19607348f809a","page_count":10,"file_size":539912,"filepath_local":"recap/gov.uscourts.vaed.544471/gov.uscourts.vaed.544471.1.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.vaed.544471/gov.uscourts.vaed.544471.1.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 3:23-cr-00138-MHL Document1 Filed 10/25/23 Page 1 of 10 PagelD# 1\n\nE\n\n|| | GT 25\n\nIN THE UNITED STATES DISTRICT COURT FOR THE\n\n223\n\nEASTERN DISTRICT OF VIRGINIA CLERIC RIGHMOND VAC\nRICHMOND DIVISION\nUNITED STATES OF AMERICA Case No. 3:23CR. 20\nv. 18 U.S.C. \u00a7 1957\nEngaging in Monetary Transactions in\nROXANNE SULLIVAN, Property Derived from Specified\nUnlawful Activity\nDefendant. (Count 1)\nForfeiture Allegation\nCRIMINAL INFORMATION\n\nTHE UNITED STATES ATTORNEY CHARGES THAT: \u00bb\nGeneral Allegations\nAt all times material to this Criminal Information, unless otherwise stated:\n\n1. The defendant, ROXANNE SULLIVAN (\u201cSULLIVAN\u201d), was a resident of\nBeaverdam, Virginia, located within the Eastern District of Virginia.\n\n2. Company 1, a company headquartered in Warrenville, Illinois, is in the business of\nproviding specialized venue transformation services. Company 1 designs, delivers, and installs\naudience risers, stadium seating, platforms, drapery, and scenery for high-end sporting, corporate,\nand other special events. Providing these services requires Company 1 employees to travel to\nevent sites located across the United States and stay on-site before, during, and after events.\nAccordingly, Company | books a significant number of hotel rooms, corporate housing, and other\nforms of lodging each year for its personnel.\n\n3. Company 1 acquired Company 2, a company headquartered in Ashland, Virginia,\nin or around August of 2016. Company 2 provided the same general services as Company 1, as it\n\nrented, delivered, assembled, and dismantled temporary seating, flooring, and camera towers for\n\fCase 3:23-cr-00138-MHL Document1 Filed 10/25/23 Page 2 of 10 PagelD# 2\n\nlarge outdoor events in the United States.\n\n4. Company 2 hired the defendant, SULLIVAN, in or around April 2012, to fill the\nfull-time, salaried position of Travel Manager. SULLIVAN\u2019s duties consisted of managing hotel\nbookings and other necessary logistics for Company 2 employee travel. As part of SULLIVAN\u2019s\nnegotiated agreement with Company 2, SULLIVAN was permitted to retain travel commissions\non any bookings she made: hotel, air, and rental car. SULLIVAN\u2019s annual salary was kept a low\n$45,000 per year because she was retaining her commissions. Company | retained SULLIVAN\nin this same position upon Company 1\u2019s acquisition of Company 2 in August of 2016.\n\n5. Prior to becoming an employee at Company 2, SULLIVAN owned and operated a\ntravel agency, Ravens World Travel (\u201cRavens World\u201d), which SULLIVAN claimed to have\noperated from December of 1999 until April of 2012. SULLIVAN was also a travel agent with the\nInternational Air Transport Association (IATA). As a travel agent, working for clients,\nSULLIVAN could earn \u201ccommissions\u201d on the bookings she completed \u2014 that is, a payment\nremitted to the travel agent by the hotel that consists of a pre-determined portion of the lodging or\ntravel accommodations purchased by the travel agent\u2019s client.\n\n6. Because a hotel is required to remit a portion of a booking customer\u2019s payment to\nthe travel agent\u2014in effect, reducing the hotel\u2019s proceeds for that transaction\u2014a_ hotel\u2019s\n\u201ccommissionable rates\u201d for hotel rooms are often more expensive than \u201cnon-commissionable\nrates,\u201d which instead allow the hotel to keep the entirety of the transaction proceeds. In extended\nstay bulk travel bookings, such as those made by SULLIVAN for Company 1, hotel bookings are\nfrequently negotiated on a case-by-case basis. In some instances, commissionable rates are higher\nthan non-commissionable rates. In some instances, commissionable rates are the same as non-\ncommissionable rates.\n\n7. In her capacity as a travel agent, SULLIVAN utilized the services of a travel advisor\n\n2\n\fCase 3:23-cr-00138-MHL Document1 Filed 10/25/23 Page 3 of 10 PagelD# 3\n\nagency named Nexion. Among other services, Nexion allows travel agent users to process their -\nhotel and travel booking commissions through Nexion (in effect, hotels and other travel-related\nbusinesses will transfer a travel agent\u2019s booking commissions to Nexion, which processes the\ncommission and remits the proceeds to the travel agent). Nexion remitted SULLIVAN\u2019s\ncommission payments to a bank account SULLIVAN created for Ravens World Travel at BB&T\nBank (now Truist Financial), a financial institution as that term is defined at 18 U.S.C. \u00a7 20.\nSULLIVAN also maintained a personal bank account at BB&T Bank (account number ending .\n6095).\n\n8. When making the decision to retain SULLIVAN as a Company | employee when\nacquiring Company 2, Company 1 did not hire or engage SULLIVAN\u2019s Ravens World Travel, or\notherwise agree to or intend to enter into a travel agent-client relationship with Ravens World\nTravel. Rather, Company 1 understood it was retaining SULLIVAN as a full-time, salaried\nemployee, responsible\u2014as the company\u2019s in-house Travel Manager\u2014for booking adequate and\n\nacceptable travel arrangements and accommodations at the best possible price for her employer.\n\nThe Scheme and Artifice to Defraud\n\n9. From at least in or around August of 2016, and continuing through on or about July\n20, 2022, in the Eastern District of Virginia and within the jurisdiction of this Court, as well as\nelsewhere, the defendant, ROXANNE SULLIVAN, knowingly, unlawfully, and with intent to\ndefraud, executed and attempted to execute a scheme and artifice to defraud her employer,\nCompany 1, and to obtain money, funds, and property belonging to Company 1, by means of\nmaterially false and fraudulent pretenses and promises, and for the purpose of executing this\nscheme, and attempting to do so, caused to be transmitted by means of wire communication in\n\ninterstate commerce certain signals and sounds.\n\fCase 3:23-cr-00138-MHL Document1 Filed 10/25/23 Page 4 of 10 PagelD# 4\n\nPurpose of the Scheme and Artifice to Defraud\n10. _ The purpose of the scheme and artifice to defraud was for SULLIVAN to\n\nunlawfully enrich herself by arranging for Company 1 to pay higher \u201ccommissionable\u201d rates for\nhotel rooms, rather than the lower, corporate (but non-commissionable) rates that were otherwise\navailable to Company 1, and subsequently directing the commissions\u2014that is, Company 1\u2019s over-\n\npayments\u2014for these hotel bookings to her Ravens World bank account at BB&T.\n\nManner and Means of the Scheme and Artifice to Defraud\n\n11. The manner and means of the scheme and artifice to defraud included, but were not\nlimited to, the following:\n\na. In her capacity as Company 1\u2019s Travel Manager, SULLIVAN was entrusted with\nthe autonomy to select and purchase hotel accommodations for Company 1\u2019s\ntraveling employees. To this end, SULLIVAN would contact hotel chain\nrepresentatives to solicit and evaluate hotel rates and accommodation offerings.\n\nb. Those hotel representatives would provide SULLIVAN with the hotel room costs\nthat Company 1 could expect to pay for Company 1\u2019s hotel room reservation(s); in\nsome cases, the representative would offer Sullivan non-commissionable (that is,\nlower-cost) room rates.\n\nc. Rather than soliciting or accepting the hotel chains\u2019 representatives\u2019 lowest non-\ncommissionable rate room prices, however, SULLIVAN would instead direct the\nhotel representatives to provide her with lowest commissionable room rates\u2014that\nwas, at times, a higher rate for the same rooms.\n\nd. As a result of SULLIVAN\u2019s deliberate selection of commissionable room rates,\n\nSULLIVAN\u2019s employer, Company 1, sometimes paid a higher cost for the hotel\n\fCase 3:23-cr-00138-MHL Document 1 Filed 10/25/23 Page 5 of 10 PagelD# 5\n\nrooms in question than they would have been required to pay had SULLIVAN\nrequested only the lowest non-commissionable room rate.\n\ne. In instances when the commissionable rate was higher than the non-\ncommissionable rate, the hotel chain would then remit the additional funds\n(unwittingly) expended by Company 1\u2014that is, SULLIVAN\u2019s commission\u2014to\nSULLIVAN, typically through SULLIVAN\u2019s Nexion account for Ravens World\nTravel. SULLIVAN would subsequently transfer those fraudulently-obtained\nfunds from her Nexion account to her Ravens World bank account at BB&T Bank.\nSULLIVAN would then use those fraudulently-obtained funds for her own\npurposes.\n\nExecution of the Scheme and Artifice\n\n12, _ Between in or around August of 2016, and continuing through on or about July 20,\n2022, in the Eastern District of Virginia and within the jurisdiction of this Court, as well as\nelsewhere, for the purpose of executing and attempting to execute the scheme and artifice to\ndefraud, defendant ROXANNE SULLIVAN caused to be sent and delivered in interstate and\nforeign commerce via wire communication certain signs, signals, and writings\u2014notably, email\ncommunications between SULLIVAN, operating from an office in Ashland, Virginia, and\nrepresentatives of numerous national hotel chains operating from states and commonwealths other\nthan the Commonwealth of Virginia.\n\n13. At all times, SULLIVAN knew and understood that her commissionable rate\nscheme resulted in her employer, Company 1, sometimes being charged more for hotel\naccommodations than was required to secure the room reservations in question. SULLIVAN\ndeliberately directed hotel representatives to provide SULLIVAN with commissionable room\n\nrates, knowing and intending that Company 1 could be paying a higher rate\u2014and that Company\n\n5\n\fCase 3:23-cr-00138-MHL Document1 Filed 10/25/23 Page 6 of 10 PagelD# 6\n\n1\u2019s additional expenditure would be routed not to the hotel chain in question, but to SULLIVAN\u2019s\nown bank account. Representative examples of SULLIVAN\u2019s deliberate insistence on the addition\n\nof her commission to Company 1\u2019s total costs include the following.\n\nOn or About Date SULLIVAN Correspondence\n\nFeb. 6, 2020 SULLIVAN corresponds with a representative of Sonesta International\nHotels Corporation for the purpose of booking hotel rooms for a\nCompany 1 crew in Georgia. After receiving the available rates from\nthe hotel representative, SULLIVAN states that \u201cJ forgot to tell you Iam\na travel agent and need Commissionable rates.\u201d The hotel\nrepresentative confirms that the rates can be increased 10 percent to\naccommodate SULLIVAN\u2019s demand for commissions.\n\nDec. 13, 2021 SULLIVAN corresponds with a representative of My Place Hotels for\nthe purpose of booking hotel rooms for Company |] employees in\nLebanon, Tennessee.\n\n- Among other questions, the hotel chain representative asks if\nthis transaction would require a commission.\n\n- SULLIVAN responds: \u201cPlease add the standard 10%\nCommission to all rates,\u201d\n\nApril 11, 2022 SULLIVAN corresponds with a representative of the Midwest Lodging\nGroup (a Hilton subsidiary) for the purpose of booking hotel rooms for\na Company | crew in Michigan.\n\n- The representative explains that the hotel can offer rooms for\n$109.00 per night.\n\n- SULLIVAN responds \u201cWill the $109 rate be\nCommissionable[?]\u201d\n\n- The representative responds \u201cYes, it can be, what is the\ncommission %? Standard for Hilton is 7%.\u201d\n\n- SULLIVAN responds, \u201cJ normally get 10%\u201d\n\n- The hotel representative subsequently confirms that the hotel can\ndo \u201cthe $109 w/ 10% commission.\u201d\n\n14. SULLIVAN knew and understood that her employer had not authorized her\ncommissionable rate scheme, and that if Company 1 learned of SULLIVAN\u2019s scheme to route\n\nCompany | travel budget funds into her own bank account, SULLIVAN\u2019s ability to continue to\n\fCase 3:23-cr-00138-MHL Document1 Filed 10/25/23 Page 7 of 10 PagelD# 7\n\nprofit from the scheme would come to a sudden end. Accordingly, SULLIVAN took deliberate\nsteps to conceal her activities from Company 1 management. SULLIVAN\u2019s efforts at concealment\nincluded, for example:\n\na. On or about January 23, 2020, a representative of the Wyndham Hotel Group\nemailed SULLIVAN a quote for hotel rooms at a \u201c$105 commissionable\u201d rate and\nanother set of rooms at a \u201c$119 commissionable\u201d rate. SULLIVAN, who in this\ninstance needed approval from Company 1 management due to the exigent nature\nof the travel plans in question, forwarded the Wyndham representative\u2019s email to\nCompany 1\u2019s Executive Vice President of Operations, but edited that email to\nremove the word \u201ccommissionable\u201d from the representative\u2019s quote for $119.\n\nb. On or about February 18, 2021, SULLIVAN responded to a reservation\nconfirmation email from a representative of Wyndham Hotels. SULLIVAN was\nirate that the hotel reservation confirmation language directly referenced\nSULLIVAN\u2019s commissions. SULLIVAN wrote to the hotel representative, in all\ncaps, that \u201cI THOUGHT YOU CHANGE[D] THE LANGUAGE ON THESE\nCONFIRMATIONS I WILL STOP USING WYNDHAM IF THEY CAN\u2019T GET\nRID OF IT. I CAN\u2019T HAVE IT COST ME MY MONEY.\u201d\n\n\u00a2. On or about March 10, 2021, SULLIVAN emailed a representative of Choice\nHotels regarding a contract between Company 1 and Choice Hotels. SULLIVAN\nexplained that she had reviewed the draft contract, and requested that a reference\nto SULLIVAN\u2019s commissions be deleted from the contract, \u201cas commission is not\npaid to [Company 1].\u201d When the hotel representative responded that Choice\nHotel\u2019s legal team was unable to remove the commission line, SULLIVAN\n\ninstructed the representative to \u201c[g]o back to them and tell them that they don\u2019t want\n\n7\n\fCase 3:23-cr-00138-MHL Document 1 Filed 10/25/23 Page 8 of 10 PagelD# 8\n\nme exposing there [sic.] agreement with anyone nor do I want them disclosing my\nagreement with choice with my customer.\u201d\n\n15. Company 1 senior management learned of SULLIVAN\u2019s commissionable rate\nscheme in June of 2022 from an individual who had been employed by Company 1\u2014briefly\u2014as\na \u201cTravel Assistant,\u201d working directly for SULLIVAN. Company | management questioned\nSULLIVAN during a meeting on or about July 20, 2022. During that meeting, SULLIVAN\ninitially denied aspects of her scheme\u2014for example, disputing that she had ever asked hotel\nrepresentatives to remove references to commissions from Company 1 contracts\u2014before\neventually admitting to her actions and conceding that she had in fact directed the removal of\ncommission references in order to conceal the fact of the commissions from Company 1 so that\nthe commissions \u201cdon\u2019t stop.\u201d\n\n16. On August 10, 2023, federal agents visited SULLIVAN at her Beaverdam\nresidence. After introducing themselves and providing their credentials, the agents\u2014a Special\nAgent with Internal Revenue Service Criminal Investigation and a Special Agent with the Federal\nBureau of Investigation\u2014explained to SULLIVAN that they were engaged in an investigation\nrelated to her tenure at Company 1. SULLIVAN, without consulting a lawyer, agreed to speak\nwith the agents, and during the ensuing interview, made numerous, knowingly false\nrepresentations regarding the above-described commission scheme. Those statements were\nmaterial to the agents\u2019 investigation, which was itself a matter within the jurisdiction of the\nExecutive branch of the United States government. SULLIVAN\u2019s willful misrepresentations\nincluded the following:\n\na. SULLIVAN claimed that she had explicitly informed Company 1\u2019s former Chief\nExecutive Officer (CEO) (the Company 1 employee who had made the decision to\n\nretain SULLIVAN in the position as Travel Manager) about her intent to continue\n\n8\n\fCase 3:23-cr-00138-MHL Document1 Filed 10/25/23 Page 9 of 10 PagelD# 9\n\nusing her Ravens World Travel company to collect commissions on the reservations\nSULLIVAN would now be booking for Company 1, and that the former CEO\nsubsequently agreed to SULLIVAN\u2019s proposal and understood that Company 1\nwould be a \u201cclient\u201d of SULLIVAN\u2019s Ravens World Travel company. In fact, as\nSULLIVAN well knew, SULLIVAN had not informed Company 1\u2019s CEO that she\nwas retaining commissions, and Company 1 had not agreed to become a client of\nSULLIVAN\u2019s Ravens World Travel company.\n\nb. SULLIVAN told the agents that she \u201cnever outright asked for commissions from\nhotels,\u201d and instead had left that decision (whether to provide SULLIVAN with a\ncommissionable rate) up to the hotels\u2019 discretion. In fact, as SULLIVAN well\nknew, SULLIVAN routinely and consistently instructed hotel representatives that\nSULLIVAN would require commissionable rates as a condition of booking\naccommodations at the hotel.\n\nce. SULLIVAN claimed that during her 10-plus years of employment at both Company\n2 and Company 1, SULLIVAN had made a total of \u201cmaybe $500,000\u201d in\ncommissions. In fact, as SULLIVAN well knew, SULLIVAN had received more\n\nthan $1,000,000 in commission payments during her tenure with Company | alone.\n\n\u2018 COUNT ONE\n(Engaging in Monetary Transactions in Property Derived from Specified Unlawful Activity)\n\n17. The allegations contained in Paragraphs | through 16 are realleged and\nincorporated as though set forth in full here.\n\n18. Onor about July 15, 2020, in the Eastern District of Virginia, the defendant,\nROXANNE SULLIVAN, did knowingly engage and attempt to engage in a monetary transaction\n\nby, through, or to a financial institution, affecting interstate or foreign commerce, in criminally\n\n9\n\fCase 3:23-cr-00138-MHL Document 1. Filed 10/25/23 Page 10 of 10 PagelD# 10\n\nderived property of a value greater than $10,000, that is, the deposit of some $74,000 of U.S.\ncurrency into SULLIVAN\u2019s personal bank account (ending in -6095) at BB&T Bank, such\nproperty having been derived from a specified unlawful activity, that is, Wire Fraud, in violation\nof 18 U.S.C. \u00a7 1343.\n\n(In violation of Title 18, United States Code, Section 1957.)\n\nFORFEITURE\nPursuant to 32.2 of the Federal Rules of Criminal Procedure, the defendant is hereby\nnotified that, upon conviction of Count One of this Criminal Information, the defendant shall\nforfeit to the United States any property, real or personal, involved in the offense, or any property\ntraceable to such property, pursuant to 18 U.S.C. \u00a7 982(a)(1).\nIf any property subject to forfeiture cannot be located, the United States will seek an order\nforfeiting substitute assets.\n(All in accordance with Title 18, United States Code, Section 982(a)(1) and Title 21, United\n\nStates Code, Section 853(p).)\n\nJESSICA D,. ABER\nUNITED STATES ATTORNEY\n\nBy: Ate\n\nThomas A. Garnett\nAssistant United States Attorney\n\n10\n","ocr_status":1,"date_upload":"2023-10-27T11:16:15.786084-07:00","document_number":"1","attachment_number":null,"pacer_doc_id":"189012990046","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""}],"date_created":"2023-10-27T11:16:01.606245-07:00","date_modified":"2023-10-27T11:16:01.609347-07:00","date_filed":"2023-10-25","time_filed":null,"entry_number":1,"recap_sequence_number":"2023-10-25.001","pacer_sequence_number":4,"description":"CRIMINAL INFORMATION as to Roxanne Sullivan count 1. (Kat) (Entered: 10/25/2023)","tags":[]}],"entries_total":"https://www.courtlistener.com/api/rest/v4/docket-entries/?count=on&docket=67921622&page_size=40"}