Reece

MEMORANDUM *

Between September 1997 and August 2001, Kirm Kath (“Kath”) coordinated a scheme to defraud the government whereby he bribed various officials of the Indian Health Service (“IHS”) and Bureau of Indian Affairs (“BIA”) to make purchases from companies that Kath either owned or represented. The products ordered, some of which were never delivered, were purchased in excess of need and sold at inflated prices. In all, six government and three tribal employees received a total of 97 kickback payments from Kath or Kath operatives, resulting in an estimated loss to the United States of $192,015.52.

From October 1997 to autumn 2001, IHS employee Keith Reece (“Reece”) authorized 28 government credit card purchases totaling $43,922 from Kath, in excess of $18,854 over the government’s needs. During the same period, Kath wired Reece 12 kickback payments totaling $3,696.

Another IHS employee, Arthur Alden (“Alden”), made approximately 36 purchases of lighting supplies from Kath totaling $80,990 between 1997 and 1999. These transactions resulted in a total overcharge to the IHS of approximately $33,098. Between January 1997 and July 1999, Kath sent 42 wire transfers to Alden…