UNITED STATES OF AMERICA, V. [1] JULIA BEATRICE KELEHER: The charges of wire fraud are known to be very broad and non-specific.This case has to be scrutinized for the signs of the politicization. To me, this whole affair smells strongly as being political and the retaliation on the part of Trump: to teach Rossello a lesson for his opposition and harsh words.

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF PUERTO RICO
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UNITED STATES OF AMERICA,
V.
[1] JULIA BEATRICE KELEHER,
Counts: 1-3, 10,12, 15-16,
[2] ANGELA AVILA-MARRERO,
A/K/A “ANGIE”
Counts: 19-23,25
[3] ALBERTO VELAZQUEZ-PINOL,
Counts: 12-32
[4] FERNANDO SCHERRER-CAILLET,
Counts: 16,19,23-26,
[5] GLENDA E. PONCE-MENDOZA,
Counts: 1,4-11
[6] MAYRA PONCE-MENDOZA,
Counts: 1,3-6,9, 11
Defendants.
INDICTMENT
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CRIMINAL NO. 19-^, r’tf>/)C^
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CRIMINAL VIOLATIONS:
18U.S.C.§ 1349
(Wire Fraud Conspiracy) Count 1
18U.S.C.§§371,641
(Conspiracy, Theft) Counts 12, 19
18US.C. § 1343
(Wire Fraud) Counts 2-11, 13-18, 20-25
18U.S.C.§1956(h)
(Money Laundering Conspiracy) Count 26
18U.S.C. § 1957
(Money Laundering) Counts 27-32
32 COUNTS
& FORFEITURE ALLEGATIONS
INDICTMENT
THE GRAND JURY CHARGES:
COUNT ONE
18 U.S.C. § 1349
(Conspiracy to Commit Wire Fraud)
Unless otherwise specified, at all times material to this Indictment:
1. The Puerto Rico Department of Education (hereinafter “PR DOE”) was organized under
Article V, section 6 of the Constitution of the Commonwealth of Puerto Rico. The PR DOE
was responsible for the planning and administration of all public elementary, secondary
Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 1 of 44
and some post-secondary education throughout Puerto Rico.
2. The PR DOE administered various federal financial assistance programs funded by the
United States Department of Education (hereinafter “US ED”) intended for students in
public and private schools.
3. Keleher & Associates, LLC (hereinafter “Keleher & Associates ) was a foreign for-profit
limited liability company organized under the laws of the District of Columbia and duly
authorized to do business in Puerto Rico from on or about April 21,2015, until on or about
January 25, 2018.
4. Keleher & Associates was owned and managed by [1] JULIA BEATRICE KELEHER
from April 21, 2015, until at least in or about 2017.
5. Keleher & Associates maintained a corporate bank account at Wells Fargo Bank, NA
managed and controlled by [1] JULIA BEATRICE KELEHER until at least In or about
June 2018.
6. On or about January 25, 2018, Individual A, an official of Keleher & Associates, was
authorized to execute all legal and administrative documents to “renounce” authorization
to do business in Puerto Rico.
7. [1] JULIA BEATRICE KELEHER was the Secretary of PR DOE from in or about
January 2017 until on or about April 1, 2019. While serving as Secretary of PR DOE, [1]
JULIA BEATRICE KELEHER was paid via professional services contracts by The
Puerto Rico Fiscal Agency and Financial Advisory Authority (hereinafter “FAFAA” or
“AAFAF”).
8. The PR DOE utilized divisions and units within the PR DOE to manage different functions
and to coordinate the activities of the PR DOE. One such division within the PR DOE was
Case 3:19-cr-00431-PAD Document 3 Filed 07/09/19 Page 2 of 44
the “Secretaria Auxiliar de Asuntos Federales” (Federal Affairs) unit, managed and
overseen by the “Secretaria AuxiUar” (Director).
9. Individual B was the Director of Federal Affairs from in or about January 2017 until in or
about August 2017. As such, she had authority to seek services for the unit, including via
requests for proposals under the PR DOE regulations.
10. In or about January 2017, [5] GLENDA E. PONCE-MENDOZA began working in PR
DOE representing herself to be Special Assistant to the Secretary. At that time, she was
not an employee nor had a contract with the PR DOE.
11. On or about March 28, 2017, [5] GLENDA E. PONCE-MENDOZA executed a
professional services contract to serve as a consultant for PR DOE. The professional