Lyons

BACKGROUND

I. FACTUAL BACKGROUND

We first describe the scheme Lyons and Sanchez devised, and then turn to the specific representations made to potential donors through both telemarketers and promotional pam- phlets, and how Lyons and Sanchez actually spent the funds they received.

A. OVERVIEW OF THE SCHEME

Around early 1994, long-time friends Lyons and Sanchez decided to form a business in which Sanchez would run a church and Lyons would supervise telemarketers to raise money for the church. Sanchez formed the First Church of Life (FCL), which had no congregation, services or place of worship; its address belonged to the house of Sanchez’s father. Lyons formed a fundraising company called North American Acquisitions (NAA).

In pursuit of their scheme, the pair created six charities under the FCL umbrella and selected names likely to attract sympathy and donations, including the AIDS Research Asso- ciation, Children’s Assistance Foundation, Cops and Sheriffs 7848 UNITED STATES v. LYONS of America, Handicapped Youth Services, U.S. Firefighters, and U.S. Veterans League. None of these charities had infra- structure separate from FCL. The groups also had…