IN THE TERRITORIAL COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
GOVERNMENT OF THE VIRGIN ISLANDS)
Plaintiff, ) )
vs. ) CRIMINAL NO. F ___/00
)
ROY L. SCHNEIDER )
ALVIN BATTISTE )
MAREEN BRYAN )
DEAN WALLACE )
Defendant )
INFORMATION
THE GOVERNMENT OF THE VIRGIN ISLANDS CHARGES THAT
COUNT ONE
On or about October 29, 1998, in St. Thomas, US Virgin Islands, Roy L. Schneider, Maureen Bryan and Alvin Battiste did present a claim upon a Department of the Government of the Virgin Islands, knowing such claim to be fraudulent in that:
1. Roy L. Schneider was then the Governor of the Virgin Islands
2. Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
3. Maureen Bryan was then the Executive Assistant to Roy Schneider
4. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
5. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
6. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
7. On October 29, 1998, Roy L. Schneider caused an MDV (MDV #0020-99) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider stated in said MDV that payment in the amount of $29,402.55 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by an essential government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
8. Roy L. Schneider knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on October 29, 1998.
9. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
10. Maureen Bryan instructed Alvin Battiste to draft a memorandum to the Department of Finance in support of the payment, stating that the room had been occupied by John (Jean) Greaux, who at the time was a government employee, knowing that Walter Brunner (and not John Greaux), resided in the room
11. Said memorandum was submitted to the Department of Finance in support of the MDV
and thus Roy Schneider, Maureen Bryan and Alvin Batiste committed the crime of Fraudulent Claims Upon the Government in violation of 14 VIC 843(1)
COUNT TWO
On or about October 29, 1998, in St. Thomas, US Virgin Islands, Roy L. Schneider Maureen Bryan and Alvin Battiste did knowingly and willfully falsify a material fact in a matter within the jurisdiction of a department of the government of the Virgin Islands in that
1. Roy L. Schneider was then the Governor of the Virgin Islands
2. Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
3. Maureen Bryan was then the Executive Assistant to Roy Schneider
4. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
5. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
6. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
7. On October 29, 1998, Roy L. Schneider caused an MDV (MDV #0020-99) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider stated in said MDV that payment in the amount of $29,402.55 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by an essential government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
8. Roy L. Schneider knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on October 29, 1998.
9. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
10. Maureen Bryan instructed Alvin Battiste to draft a memorandum to the Department of Finance in support of the payment, stating that the room had been occupied by Jean Greaux, (and not John Greaux), who at the time was a government employee, knowing that Walter Brunner resided in the room
11. Said memorandum was submitted to the Department of Finance in support of the MDV
and thus Roy Schneider, Maureen Bryan and Alvin Batiste committed the crime of Fraudulent Claims Upon the Government in violation of 14 VIC 843(2)
COUNT THREE
On or about December 29, 1998, in St. Thomas, US Virgin Islands, Dean Wallace was a public officer, and appropriated public monies to the use of another without authority of law in that:
1. Dean Wallace was the then Acting Commissioner of the Department of Finance
2. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors with public funds
3. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
4. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
5. On October 29, 1998, Roy L. Schneider caused an MDV (MDV #0020-99) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider stated in said MDV that payment in the amount of $29,402.55 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by an essential government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
6. Roy L. Schneider knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on October 29, 1998.
7. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Mag
en’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
8. Maureen Bryan instructed Alvin Battiste to draft a memorandum to the Department of Finance in support of the payment, stating that the room had been occupied by John (Jean) Greaux, who at the time was a government employee, knowing that Walter Brunner (and not John Greaux), resided in the room
9. Said memorandum was submitted to the Department of Finance in support of the MDV
10. Ms. Paulette Rabsatt was the then director of Accounting at the Department of Finance. On or about November 5th, she informed Dean Wallace that she had reviewed MDV 0020-99, and that the MDV was not appropriate for payment. He was also informed that same day by Ms. Rabsatt that a prior MDV, (MDV 0511-96), had been submitted in the past for the same bill and rejected.
11. Ms. Rabsatt was subsequently terminated on November 20, 1998, and Dean Wallace ordered one Delores Hodge, on December 29, 1998 to process the MDV, in spite of being informed of it’s impropriety
and thus Dean Wallace committed the crime of Embezzlement or Falsification of Public Accounts in violation of 14 VIC 1662(1)
COUNT FOUR
On or about December 29, 1998, in St. Thomas, US Virgin Islands, Roy Schneider, Maureen Bryan, Alvin Battiste and Dean Wallace did conspire to commit the crime of Embezzlement of Public Funds, in that each was a public officer, and agreed to, and then appropriated, public monies to the use of another without authority of law in that:
1. Roy L. Schneider was then the Governor of the Virgin Islands
2. Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
3. Maureen Bryan was then the Executive Assistant to Roy Schneider
4. Dean Wallace was the then Acting Commissioner of the Department of Finance
5. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors with public funds
6. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
7. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
8. On October 29, 1998, Roy L. Schneider caused an MDV (MDV #0020-99) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider stated in said MDV that payment in the amount of $29,402.55 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by an essential government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
9. Roy L. Schneider knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on October 29, 1998.
10. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
11. Maureen Bryan instructed Alvin Battiste to draft a memorandum to the Department of Finance in support of the payment, stating that the room had been occupied by John (Jean) Greaux, who at the time was a government employee, knowing that Walter Brunner (and not John Greaux), resided in the room
12. Said memorandum was submitted to the Department of Finance in support of the MDV
13. Ms. Paulette Rabsatt was the then director of Accounting at the Department of Finance. On or about November 5th, she informed Dean Wallace that she had reviewed MDV 0020-99, and that the MDV was not appropriate for payment. He was also informed that same day by Ms. Rabsatt that a prior MDV, (MDV 0511-96), had been submitted in the past for the same bill and rejected.
14. Ms. Rabsatt was subsequently terminated on November 20, 1998, and Dean Wallace ordered one Delores Hodge, on December 29, 1998 to process the MDV, in spite of being informed of it’s impropriety
and thus, Roy Schneider, Maureen Bryan, Alvin Battiste and Dean Wallace committed the crime of Conspiracy and Falsification of Public Accounts in violation of 14 VIC 1662(1) and 551(1)
COUNT FIVE
On or about December 29, 1998, in St. Thomas, US Virgin Islands, Roy Schneider, Maureen Bryan, Alvin Battiste, being public officers authorized by law to make a writing, did make and deliver as true such a writing, when that writing contained statements which they knew to be false, in that:
1. Roy L. Schneider was then the Governor of the Virgin Islands
2. Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
3. Maureen Bryan was then the Executive Assistant to Roy Schneider
4. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
5. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
6. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
7. On October 29, 1998, Roy L. Schneider caused an MDV (MDV #0020-99) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider stated in said MDV that payment in the amount of $29,402.55 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by an essential government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
8. Roy L. Schneider knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on October 29, 1998.
9. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
10. Maureen Bryan instructed Alvin Battiste to draft a memorandum to the Department of Finance in support of the payment, stating that the room had been occupied by John (Jean) Greaux, who at the time was a government employee, knowing that Walter Brunner (and not John Greaux), resided in the room
11. Said memorandum was submitted to the Department of Finance in support of the MDV
and thus, Roy Schneider, Maureen Bryan, and Alvin Battiste committed the crime of False Certificate by Public Officer in violation of 14 VIC 1664
COUNT SIX
On or about July 11, 1996, in St. Thomas, US Virgin Islands, Roy L. Schneider and Alvin Battiste did present a claim upon a Department of the Governmen
t of the Virgin Islands, knowing such claim to be fraudulent in that:
1. Roy L. Schneider was then the Governor of the Virgin Islands and Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
2. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
3. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
4. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
5. On July 11, 1996 Roy L. Schneider and Alvin Battiste caused an MDV (MDV #0511-96) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider and Alvin Battiste stated in said MDV that payment in the amount of $29,402.55 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by an essential government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
6. Roy L. Schneider and Alvin Battiste knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on July 11, 1996.
7. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
and thus, Roy L. Schneider and Alvin Battiste committed the crime of Fraudulent Claims Upon the Government in violation of 14 VIC 843(1)
COUNT SEVEN
On or about July 11, 1996, in St. Thomas, US Virgin Islands, Roy L. Schneider and Alvin Battiste did knowingly and willfully falsify a material fact in a matter within the jurisdiction of a department of the government of the Virgin Islands in that:
1. Roy L. Schneider was then the Governor of the Virgin Islands and Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
2. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
3. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
4. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
5. On July 11, 1996 Roy L. Schneider and Alvin Battiste caused an MDV (MDV #0511-96) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider and Alvin Battiste stated in said MDV that payment in the amount of $29,402.55 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by an essential government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
6. Roy L. Schneider and Alvin Battiste knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on July 11, 1996.
7. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
and thus Roy L. Schneider and Alvin Battiste committed the crime of Fraudulent Claims Upon the Government in violation of 14 VIC 843(2)
COUNT EIGHT
On or about July 11, 1996, in St. Thomas, US Virgin Islands, Roy L. Schneider and Alvin Battiste , being public officers authorized by law to make a writing, did make and deliver as true such a writing, when that writing contained statements which they knew to be false, in that:
1. Roy L. Schneider was then the Governor of the Virgin Islands and Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
2. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
3. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
4. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
5. On July 11, 1996 Roy L. Schneider and Alvin Battiste caused an MDV (MDV #0511-96) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider and Alvin Battiste stated in said MDV that payment in the amount of $29,402.55 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by an essential government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
6. Roy L. Schneider and Alvin Battiste knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on July 11, 1996.
7. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
and thus Roy L. Schneider and Alvin Battiste committed the crime of False Certificate by Public Officer in violation of 14 VIC 1664
COUNT NINE
On or about March 14, 1996, in St. Thomas, US Virgin Islands, Roy L. Schneider and Alvin Battiste did present a claim upon a Department of the Government of the Virgin Islands, knowing such claim to be fraudulent in that:
1. Roy L. Schneider was then the Governor of the Virgin Islands and Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
2. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
3. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a M
DV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
4. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
5. On March 14, 1996 Roy L. Schneider and Alvin Battiste caused an MDV (MDV #0298-96) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider and Alvin Battiste stated in said MDV that payment in the amount of $3,435.20 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by a government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
6. Roy L. Schneider and Alvin Battiste knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on March 14, 1996.
7. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
and thus Roy L. Schneider and Alvin Battiste committed the crime of Fraudulent Claims Upon the Government in violation of 14 VIC 843(1)
COUNT TEN
On or about March 14, 1996, in St. Thomas, US Virgin Islands, Roy L. Schneider and Alvin Battiste did knowingly and willfully falsify a material fact in a matter within the jurisdiction of a department of the government of the Virgin Islands in that:
1. Roy L. Schneider was then the Governor of the Virgin Islands and Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
2. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
3. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
4. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
5. On March 14, 1996 Roy L. Schneider and Alvin Battiste caused an MDV (MDV #0298-96) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider and Alvin Battiste stated in said MDV that payment in the amount of $3,435.20 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by a government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
6. Roy L. Schneider and Alvin Battiste knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on March 14, 1996.
7. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
and thus Roy L. Schneider and Alvin Battiste committed the crime of Fraudulent Claims Upon the Government in violation of 14 VIC 843(2)
COUNT ELEVEN
On or about March 14, 1996, in St. Thomas, US Virgin Islands, Roy L. Schneider and Alvin Battiste being public officers authorized by law to make a writing, did make and deliver as true such a writing, when that writing contained statements which they knew to be false, in that
1. Roy L. Schneider was then the Governor of the Virgin Islands and Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
2. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
3. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
4. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
5. On March 14, 1996 Roy L. Schneider and Alvin Battiste caused an MDV (MDV #0298-96) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider and Alvin Battiste stated in said MDV that payment in the amount of $3,435.20 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by a government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
6. Roy L. Schneider and Alvin Battiste knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on March 14, 1996.
7. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
and thus Roy L. Schneider and Alvin Battiste committed the crime of False Certificate by Public Officer in violation of 14 VIC 1664
COUNT TWELVE
On or about March 28, 1996, in St. Thomas, US Virgin Islands, Roy L. Schneider and Alvin Battiste did present a claim upon a Department of the Government of the Virgin Islands, knowing such claim to be fraudulent in that:
1. Roy L. Schneider was then the Governor of the Virgin Islands and Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
2. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
3. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
4. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
5. On March 28, 1996 Roy L. Schneider and Alvin Battiste caused an MDV (MDV #0324-96) to be drafted and forwarded to the Virgin Islands Depar
tment of Finance. Roy L. Schneider and Alvin Battiste stated in said MDV that payment in the amount of $3,435.20 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by a government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
6. Roy L. Schneider and Alvin Battiste knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on March 28, 1996.
7. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
and thus Roy L. Schneider and Alvin Battiste committed the crime of Fraudulent Claims Upon the Government in violation of 14 VIC 843(1)
COUNT THIRTEEN
On or about March 28, 1996, in St. Thomas, US Virgin Islands, Roy L. Schneider and Alvin Battiste did knowingly and willfully falsify a material fact in a matter within the jurisdiction of a department of the government of the Virgin Islands in that:
1. Roy L. Schneider was then the Governor of the Virgin Islands and Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
2. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
3. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
4. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
5. On March 28, 1996 Roy L. Schneider and Alvin Battiste caused an MDV (MDV #0324-96) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider and Alvin Battiste stated in said MDV that payment in the amount of $3,435.20 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by a government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
6. Roy L. Schneider and Alvin Battiste knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on March 28, 1996.
7. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
and thus Roy L. Schneider and Alvin Battiste committed the crime of Fraudulent Claims Upon the Government in violation of 14 VIC 843(2)
COUNT FOURTEEN
On or about March 28, 1996, in St. Thomas, US Virgin Islands, Roy L. Schneider and Alvin Battiste being public officers authorized by law to make a writing, did make and deliver as true such a writing, when that writing contained statements which they knew to be false, in that
1. Roy L. Schneider was then the Governor of the Virgin Islands and Alvin Battiste was then the Director of Budget and Financial Management for the Office of the Governor
2. The Virgin Islands Department of Finance is a department of the government of the Virgin Islands responsible to pay government debts owed to vendors
3. An MDV (Miscellaneous Disbursement Voucher) is a document used by the Department of Finance. It is a written request by a government entity for the Department of Finance to pay a vendor bill on behalf of the requesting entity. In order to be processed, a MDV must first:
Be reviewed and signed by a designated person who is authorized to sign MDVs on behalf of the requesting entity
Be reviewed for propriety and legality by the Finance Department,
Be reviewed and checked for correctness of the payment by the Finance Department.
4. In September 1995, Hurricane Marilyn all but destroyed the island of St. Thomas. As part of the recovery effort, various government employees who had been rendered effectively homeless were housed at the Frenchman’s Reef Hotel at the government’s expense.
5. On March 28, 1996 Roy L. Schneider and Alvin Battiste caused an MDV (MDV #0324-96) to be drafted and forwarded to the Virgin Islands Department of Finance. Roy L. Schneider and Alvin Battiste stated in said MDV that payment in the amount of $3,435.20 was due to the Marriott’s Frenchman’s Reef Hotel for a room that had been occupied by a government employee John (Jean) Greaux, immediately following Hurricane Marilyn.
6. Roy L. Schneider and Alvin Battiste knew that one Walter Brunner, (and not John Greaux), actually resided in said hotel room from September 1995, and was still living in the room on March 28, 1996.
7. Walter Brunner was a personal friend of Roy Schneider, as well as a tenant at 204 Magen’s Point Resort, a condominium owned by Roy Schneider up until the condominium was destroyed by Hurricane Marilyn in September 1995. He was not then, nor had he ever been, an essential government employee.
and thus Roy L. Schneider and Alvin Battiste committed the crime of False Certificate by
Public Officer in violation of 14 VIC 1664
Respectfully Submitted,
IVER STRIDIRON
Attorney General
Dated:_________________ BY:__________________________
DOUGLAS SPROTTE, ESQ.
White Collar Crime
