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Environmental Crimes Case Bulletin
U.S. Environmental Protection Agency
Office of Criminal Enforcement, Forensics and Training
March 2013
This bulletin summarizes publicized investigative activity and adjudicated cases con-
ducted by OCEFT Criminal Investigation Division special agents, forensic specialists,
and legal support staff.
Defendants in this edition:
• Tonawanda Coke Corporation, Mark L. Kamholz — Region 2
• David Ector — Region 3
• FSD Group, LLC — Region 4
• Mark Jeffery Glover, Discount Computers, Inc. — Region 5
• Nghiem Van Tran, Nghi Cong Tran, Ngan Tien Tran, Dahn Cong Tran, Bich Dong Ngo,
Huy Ngoc Nguyen — Region 6
• Jeffrey David Gunselman — Region 6
• Norman Teltow — Region 8
• John Albert Paquette, East Point, LLC — Region 8
• Bret A. Simpson — Region 10
EPA Bulletin March 2013 1
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DEFENDANT SUMMARY:
REGION
DEFENDANTS
CASE TYPE/STATUTES
Region 2
Tonawanda Coke Corporation,
Mark L. Kamholz
CAA/RCRA/Illegal release of
benzene into air and illegal stor-
age, treatment, and disposal of
hazardous waste; obstruction of
justice
Region 3
David Ector
CWA/Illegal discharge of fill ma-
terial without a permit
Region 4
FSD Group. LLC
CAA/Illegal receipt, purchase,
and sale of ozone-depleting re-
frigerant gas that had been smug-
gled into the United States
Region 5
Mark Jeffrey Glover, Discount
Computers, Inc.
RCRA/Trafficking in counterfeit
goods and services; storing and
disposing of hazardous waste
without a permit
EPA Bulletin March 2013 2
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DEFENDANT SUMMARY:
REGION
DEFENDANTS
CASE TYPE/STATUTES
Region 6
Nghiem Van Tran, Nghi Cong
Tran, Ngan Tien Tran, Dahn Cong
Tran, Bich Dong Ngo, Huy Ngoc
Nguyen
CAA/Falsifying state emissions test
results
Region 6
Jeffrey David Gunselman
CAA/Wire fraud, money launder-
ing and false statements
Region 8
John Albert Paquette, East Point,
LLC
CWA/Illegally discharging sewage
into reservoir
Region 8
Norman Teltow
RCRA/Illegally treating hazardous
waste
Region 10
Bret A. Simpson
CAA/Failing to report a discharge
of oil, and unlawfully discharging
oil into the Columbia River
EPA Bulletin March 2013 3
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Quick Links:
•
• Trials
• Plea P
• Indictments/Informations
p. 4-9
p. 10
p. 11
p. 12
(Back to Quick Links)
International Heating and Cooling Product Distributor Sentenced for Illegal Purchase and Sale of
Smuggled Ozone-Depleting Refrigerant Gas - On March 5, 2013, FSD GROUP, LLC, a Florida cor-
poration headquartered in Miami, was convicted in federal district court for the Southern District of Florida
and sentenced in connection with the illegal receipt, purchase, and sale of ozone-depleting refrigerant gas
that had been smuggled into the United States contrary to the Clean Air Act.
FSD Group pled guilty to a one count In-
formation for knowingly receiving, buying, selling
and facilitating the transportation, concealment, and
sale of approximately 65,592 kilograms of the
ozone-depleting substance hydrochlorofluorocarbon
-22 ("HCFC-22") which had been illegally smug-
gled into the United States contrary to the Clean Air
Act. HCFC-22 is a refrigerant in widespread use
for residential heat pump and air-conditioning sys-
tems.
Immediately following the guilty plea, FSD
Group was sentenced to three years of probation
and ordered to pay a $100,000 criminal fine. As a
special condition of probation, FSD Group was ordered to implement and enforce a comprehensive Envi-
ronmental Compliance Plan. FSD Group was also ordered to forfeit to the United States $180,051, a sum
representing proceeds received as a result of the crime, and to pay duties owed to the United States Cus-
toms and Border Protection for incorrectly classified merchandise.
The Federal Clean Air Act regulates air pollutants including ozone depleting substances such as
HCFC-22. The Clean Air Act and its implementing regulations established a schedule to phase out the
production and importation of ozone-depleting substances beginning in 2002, with a complete ban starting
in 2030. To meet its obligations under an international treaty to reduce its consumption of ozone-depleting
substances, the United States issued baseline allowances for the production and importation of HCFC-22 to
individuals and companies. In order to legally import HCFC-22, you must hold an unexpended consump-
tion allowance.
According to court records, FSD Group, which also operates under the name Saez Distributors, is
an international supplier and distributor of merchandise used for heating, ventilation, air conditioning, and
refrigerator systems, including ozone-depleting substances. FSD is an original allowance holder under the
Clean Air Act, therefore, they have extensive knowledge regarding the Act's rules and prohibition involv-
ing the purchasing and illegal importation of HCFC-22. During the course of the illegal conduct and in
addition to its legal imports, FSD Group made purchases of HCFC-22 from various importers, knowing
they did not hold the required unexpended consumption allowances, totaling approximately 65,592 kilo-
grams of restricted HCFC-22, with a fair market value of approximately $733,096.
EPA Bulletin March 2013 4
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This matter and others involving the smug-
gling and distribution of ozone-depleting sub-
stances are being investigated through a multi-
agency initiative known as Operation Catch-
22. Operation Catch-22 has been successful in ob-
taining convictions of nearly a dozen individuals
and corporations at every level of the refrigerant
gas smuggling and distribution chain.
This case was investigated by EPA's Crimi-
nal Investigation Division, ICE-HSI, the Florida
Department of Environmental Protection, Criminal
Investigation Bureau, and the Miami-Dade Police
Department. It was prosecuted by Special Assistant
U.S. Attorney Jodi A. Mazer.
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Illegally smuggled HCFC-22
Maryland Man Sentenced After Pleading Guilty to Illegally Dumping Fill Material into the Chesa-
peake Bay - On March 13, 2013, DAVID ECTOR, of Lusby, Maryland, was sentenced in federal district
court for the District of Maryland to two years probation after he pleaded guilty to discharging fill material
into the Chesapeake Bay without a permit, in violation of the Clean Water Act. As a special condition of his
sentence, Ector was ordered to remove, at his own expense, all fill material discharged into the Chesapeake
Bay.
According to his plea agreement, Ector owned a cliff-front property in Calvert County. From May
28 through May 30, 2010, Ector caused large rocks (rip rap) to be dumped over the cliff-face. Ector did not
obtain a permit to put the rocks into the Chesapeake Bay, as required by the Clean Water Act. The rip rap
also scraped away soil on the cliff-face as it slid down the slope, interfering with the critical habitat of an
endangered species.
The case was investigated by EPA's Criminal Investigation Division and the U.S. Fish and Wildlife
Service, Office of Law Enforcement. It was prosecuted by Assistant U.S. Attorney David I. Salem.
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Large rocks illegally dumped into Chesapeake Bay by Ector
EPA Bulletin March 2013 5
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Used CRT monitors illegally abandoned by DCI in a
warehouse in Missouri
Michigan Computer Company Owner Sentenced for International Environmental, Counterfeiting
Crimes - On March 25, 2013, MARK JEFFREY GLOVER was sentenced in federal district court for
the Eastern District of Michigan to 30 months in prison and a $10,000 fine. His company, DISCOUNT
I COMPUTERS, INC. (DCI), was fined 2 million
dollars, including $10,839 in restitution to Michigan
landlord, for trafficking in counterfeit goods and ser-
vices. DCI was also sentenced for storing and dispos-
ing of hazardous waste without a permit. Glover
pleaded guilty to the charges on his behalf and that of
I his company in October 2012.
DCI, headquartered in Canton, Michigan,
I with warehouses in Maryland Heights, Mo., and Day-
ton, N.J., operated as a broker of used electronic
components, including computers and televisions.
DCI resold working and disassembled broken items,
selling them for scrap. A large part of DCFs business
involved exporting used cathode ray tube (CRT)
monitors to countries in the Middle East and Asia.
Egypt prohibits the importation of computer equipment more than five years old. To evade this, all
three DCI locations replaced the original factory labels on used CRT monitors with counterfeit labels,
which reflected a more recent manufacture date. Over a five-year period, DCI sent at least 300 shipments
to Egypt, with a total shipment value of at least $2.1 million, constituting more than 100,000 used CRTs
monitors.
Under federal law it is illegal to knowingly use a counterfeit mark on or in connection with goods
and services for the purpose of deceit or confusion. It is also I
illegal to store and dispose of hazardous waste, which in-
cludes certain electronic waste, or e-waste, without a per-
mit. Glass from older CRT monitors is known to contain
levels of lead, a known toxic hazardous waste. When depos-
ited in landfills, the lead can leach out and contaminate |
drinking water supplies.
These CRT monitors are required to be disposed of
as hazardous waste under the Resource Conservation and
Recovery Act. By exporting older CRTs with fraudulent
manufacture dates, Mark Jeffrey Glover sent a large quan-1
tity of older e-waste overseas, thus subjecting it to improper
recycling, increasing the potential for environmental and
human exposure to hazardous materials.
E-waste disposal is a global concern. Used electronic equipment contains more than 1,000 differ-
ent substances, including toxic heavy metals and organics that, if disposed of improperly, can cause signifi-
cant pollution problems. Improper e-waste disposal is common in third world and developing countries be-
cause they are ill equipped to conduct safe, appropriate recycling, refurbishing, and disposal. It is also
common in these countries to find black-market recycling groups that extract valuable metals from e-waste
without regard for the safety of their impoverished employees who are exposed directly to toxic materials.
This case was investigated by EPA's Criminal Investigation Division and U.S. Department of
Homeland Security-Homeland Security Investigations, Detroit. It was prosecuted by the U.S. Attorney's
Office in the Eastern District of Michigan by Assistant U.S. Attorney Jennifer Blackwell.
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EPA Bulletin March 2013 6
Counterfeit trademarked labels used by Glover and
DCI to reflect a more recent manufacture date on
used CRT monitors
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Washington Barge Owner Sentenced for Clean Water Act Violations for Oil Spill On Columbia
River -- On March 18, 2013, BRET A. SIMPSON, of Ellensburg, Washington, the owner of Principle
Metals, LLC, was sentenced in federal district court for the Western District of Washington to four
months in prison, eight months of home detention, 100
hours of community service and three years of super-
vised release. Simpson was responsible for a $22- mil-
lion- oil- clean up and salvage operation on the Colum-
bia River. He had pleaded guilty in July 2012 to two
criminal violations of the Clean Water Act; failing to
report a discharge of oil, and unlawfully discharging oil
into the Columbia River near Camas, Washington.
With his guilty plea, Simpson admitted that he
was informed about oil left on the 'Davy Crockett' barge
before salvage operations began. However, Simpson
failed to have the oil removed before workers started cut-
cofferdam and dismantled in place.
ting up the metal barge. When the first oil spill occurred in early December 2010, Simpson failed to no-
tify authorities and failed to take adequate steps to monitor the vessel or protect it from natural forces and
further structural damage. Subsequent spills in January 2011 led U.S. Coast Guard investigators to iden-
tify the 'Davy Crockett' as the source and initiate a federally funded cleanup effort. Ultimately the U.S.
Coast Guard and state authorities spent eight months and approximately $22 million to clean up the spill
and remove the derelict barge from the river.
The M/VDavy Crockett is a former U.S. Navy ship that had
been converted to a flat deck barge. Simpson's company planned to
cut the barge apart and sell the metal for scrap. Simpson assembled
a crew to begin dismantling the M/V Davy Crockett at its place of
moorage in the Columbia River in October 2010. He made no ar-
rangements to remove the fuel oil and diesel fuel from the vessel
before the scrapping operation began. On December 1, 2010, a
member of the scrapping crew cut into a structural beam of the
barge, and the ship began breaking apart and leaking oil. Neither Simpson nor anyone else with Principle
Metals LLC notified authorities about the leak. The scrapping operation was halted.
Simpson initially addressed the oil release by ceasing all scrapping operations, procuring a boom
to limit the release of oil into the Columbia River, and directing an employee to monitor vessel condi-
tions. The employee monitored vessel conditions for approximately one week following the initial release
before being relieved of his employment. Simpson took no further steps to monitor the ship, or the boom,
and took no steps to protect the barge from further structural damage. On January 19, 2011, an accumula-
tion of debris next to the barge forced it to move, and additional oil was released. The Coast Guard re-
sponded to the additional movement of the barge, and issued an administrative order for Simpson to re-
move any remaining visible oil from machinery spaces and deck tubes together with other salvage debris
from the vessel. Simpson complied and authorities believed the barge no longer posed an environmental
danger. However on January 27, 2011, additional oil was released from the vessel and state and federal
authorities immediately responded in an effort to limit environmental damage.
The case was investigated by EPA's Criminal Investigation Division, the U.S. Coast Guard, the
U.S. Coast Guard Investigative Service, the Washington State Department of Ecology, and the Oregon
Department of Environmental Quality. The case is being prosecuted by Assistant United States Attorney
James Oesterle and Special Assistant United States Attorney Lieutenant Commander Marianne Gelakoska
of the U.S. Coast Guard.
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EPA Bulletin March 2013
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Absolute
Bio-diesel Fuel Company Owner Sentenced to 188 Months in Federal Prison on Wire Fraud, Money
Laundering and False Statements Convictions - On March 29, 2013, JEFFERY DAVID GUNSEL-
MAN was sentenced in federal district court for the Northern District of Texas to 188 months in federal
prison, fined $175,000 and ordered to pay $54,973,137 in restitution, following his guilty plea in Decem-
ber 2012 to an indictment charging 51 counts of wire fraud, 24 counts of money laundering and four
counts of making false statements in violation of the Clean Air Act. Gunselman has been in custody since
July 2012.
Gunselman was the owner of
Absolute Fuels, LLC, dba Absolute Fu-
els, LLC (Absolute Fuels), which he
formed in April 2009. He was also
named as Governing Person and/or as
Registered Agent for other business en-
tities associated with Absolute Fuels,
LLC, including Absolute Fuels, LLC;
Absolute Milling, LLC; Ellipse Energy,
LLC; 21 Investments, LLC; and YGOG
Holdings, LLC. However, Gunselman
admitted that these entities are solely
alter egos of himself, as an individual, as he alone owns, manages, directs and controls each of them and
each has no separate and distinct existence from him.
Gunselman admitted that from September 2010 to October 2011, he devised a scheme to defraud
the Environmental Protection Agency by falsely representing that he was in the business of producing bio-
diesel fuel, yet Gunselman did not have a bio-diesel fuel-producing facility. Instead, Gunselman's busi-
ness operation consisted of falsely generating renewable fuel credits and selling them to oil companies
and brokers. He instructed purchasers to wire payments to a bank account he solely controlled, and as a
result, approximately $41,762,236 was deposited into that account.
From September 2010 to mid-October 2011, Gunselman conducted 51 fraudulent transactions,
which were transmitted by wire communications, that represented to the EPA that bio-diesel fuel had been
produced at the Absolute Fuels facility in Anton, Texas, when in fact, no bio-diesel fuel had been pro-
duced. This ultimately resulted in Gunselman requesting and receiving payments, by electronic funds
transfer, of approximately $41,762,236.
Regarding the money laundering convictions, during the same time period, Gunselman engaged in
monetary transactions in criminally derived property by purchasing real and personal property valued at
approximately $12 million with the funds derived from the wire fraud. Included in that property are: sev-
eral vehicles, including a Bentley, Mercedes-Benz, Lexus, Cadillac and Shelby Cobra; a Patton Military
Tank; a Gulfstream airplane, professional basketball season tickets and corporate sponsorship; and agri-
cultural, business and residential real estate.
The false statements convictions stem from Gunselman making material false statements to the
EPA, falsely claiming and representing that bio-diesel fuel, a renewable fuel, had been produced, generat-
ing renewable fuel credits, when Gunselman well knew that no bio-diesel fuel had been produced.
The case was investigated by EPA's Criminal Investigation Division and the U.S. Secret Service.
It was prosecuted by Assistant U.S. Attorneys Paulina Jacobo and Justin Cunningham, of the U.S. Attor-
ney's Office in Lubbock. Assistant U.S. Attorney John J. de la Garza handled the forfeiture.
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EPA Bulletin March 2013 8
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Six Texas Emissions Inspectors Sentenced for Falsifying State Emissions Test Results — On March
19, 2013, six residents of Arlington, Texas, who pleaded guilty to their respective roles in falsifying
Texas state emissions tests at two state-certified inspections stations in Arlington, were sentenced in fed-
eral district court for the Northern District of Texas, for falsifying Texas State emissions test results.
The Clean Air Act authorizes EPA to establish National Ambient Air Quality Standards
(NAAQS) to protect public health and welfare, and to regulate emissions of hazardous air pollut-
ants. Areas that exceed the NAAQS are known as "non-attainment areas." Depending on the amount of
pollution that exceeds the standards, areas are classified as marginal, moderate, serious, severe or ex-
treme. The North Texas Region that includes Dallas and Tarrant counties is classified as a "serious" non
-attainment area by the EPA. Vehicles are required to pass annual inspections to ensure that their emis-
sions do not exceed limits for hydrocarbons, nitrogen oxide and other compounds.
NGHIEM VAN TRAN and NGHI CONG TRAN, who each pleaded guilty to one count of con-
spiracy to violate the Clean Air Act, were sentenced 12 months and 15 months in federal prison respec-
tively. In addition, NGHIEM VAN TRAN was ordered to pay a $5,000 fine and he pleaded guilty to
one count of making a Clean Air Act false statement.
DAHN CONG TRAN, BICH DONG NGO, and HUY NGOC NGUYEN were each sentenced
to 12 months of probation, following each of their guilty pleas to one count of making a Clean Air Act
false statement. Danh Cong Tran's probation includes eight months of home confinement.
According to documents filed in the case, the inspection stations, including Mike's Autocare, and
Tommy Tech, both located in Arlington, performed approximately 7,656 fraudulent emissions tests be-
tween August 2009 and March 2011. The defendants circumvented the required emissions testing proce-
dures by substituting vehicles that would pass the emissions test in place of vehicles that had previously
failed or showed equipment malfunctions. In most instances, the vehicle needing an emissions test was
not present at Mike's or Tommy Tech when the emissions tests were conducted, and the defendants who
conducted the fraudulent tests received the necessary identifying vehicle information from Nghiem Van
Tran and Nghi Cong Tran via a text message or a handwritten slip of paper. The defendants generated
fraudulent emissions certificates and transmitted fraudulent testing results to the Texas Information Man-
agement System (TIMS) database managed by the Texas Department of Public Safety.
The defendants demanded up to $80 for each fraudulent test, well above the state-mandated maxi-
mum charge of $39.75. Proceeds from the fraudulent emissions tests were deposited into a bank account
for "Upland Investment," which was controlled by Nghiem Van Tran.
The case was investigated by EPA's Criminal Investigation Division and prosecuted by Assistant
U.S. Attorney Stephen P. Fahey.
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EPA Bulletin March 2013 9
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Trials (Back to Quick Links)
Tonawanda Coke Corporation
New York Coke Maker and Environmental Control Manager Convicted of CAA and RCRA Crimes
On March 28, 2013, TONAWANDA COKE CORPORATION
(TCC) was convicted by a federal jury in federal district court for
the Western District of New York of 11 counts of violating the
Clean Air Act and three counts of violating the Resource Conser-
vation and Recovery Act. In addition, Tonawanda Coke Environ-
mental Control Manager, MARK L. KAMHOLZ, of West Se-
neca, N.Y., was found guilty of 11 counts of violating the Clean
Air Act, one count of obstruction of justice and three counts of vio-
lating the Resource Conservation and Recovery Act. The charges
carry a maximum combined penalty up to 75 years in prison and
fines in excess of $200 million. Sentencing is scheduled for July
15,2013.
The offenses related to the release of coke oven gas con-
taining benzene into the air through an unreported pressure relief
valve. In addition, a coke-quenching tower was operated without
baffles, a pollution control device required by TCC's Title V Clean
Air Act permit designed to reduce the particulate matter that is re-
leased into the air during coke quenches.
In addition, prior to an inspection conducted by EPA in
April of 2009, Kamholz told another TCC employee to conceal the
fact that the unreported pressure relief valve, during normal opera-
tions, emitted coke oven gas directly into the air, in violation of the
TCC's operating permit. The defendants also stored, treated and
disposed of hazardous waste without a permit to do so, in violation of the Resource Conservation and Re-
covery Act. These offenses related to TCC's practice of mixing its coal tar sludge, a listed hazardous waste
that is toxic for benzene, on the ground in violation of hazardous waste regulations.
The case was investigated by EPA's Criminal Investigation Division and investigators of the New
York State Department of Environmental Conservation Police.
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Storage tank that was dismantled for scrap
metal and released coal tar sludge material
that tested positive for benzene
Coal tar concrete pad where decanter tank tar
sludge (K087 - listed hazardous waste) should have
been mixed with coal prior to placing the mixture
into the coke oven battery
East Quench Tower that required the installation
of baffles for particulate emission control per
the Title V air permit
EPA Bulletin March 2013 10
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Plea Agreements (Back to Quick Links)
Owner of Colorado Aircraft Painting Company Pleads Guilty to Unlawfully Treating Hazardous
Waste -- On March 12, 2013, NORMAN TELTOW, owner of Gold Metal Paint Co. LLC (GMP),
pleaded guilty in federal district court in Denver to a criminal information charging him with illegally treat-
ing hazardous waste at the company's facility. Teltow, who will be sentenced on June 10, 2013, faces a
maximum sentence of five years in prison, a $250,000 fine, and three years of supervised release.
Teltow operated GMP out of a hangar near the Front
I Range Airport in Watkins, Colo. GMP was primarily in the
business of painting small aircraft. During the course of its
business, GMP created hazardous waste in the form of
spent methylene chloride-based solvents mixed with paint
waste. Methylene chloride, a listed hazardous waste, is
both ignitable and toxic. Moreover, exposure to methylene
chloride can cause skin irritation, headache, dizziness, nau-
sea, and vomiting.
Under the Resource Conservation and Recovery
I Act, GMP was required to use a licensed waste manage-
ment company to transport the hazardous waste to a li-
censed facility for disposal. To avoid the costs associated
with proper disposal, Teltow directed GMP employees to
store the spent solvents in an underground tank below the
facility, knowing that it was illegal to store the waste in that
manner.
When the Colorado Department of Public Health
and Environment (CDPHE) became aware that Teltow and
GMP were storing hazardous waste in an underground tank,
the agency conducted an inspection and ordered Teltow to
hire a licensed waste management company to pump the
Gold Metal Paint Co. stripper hangar showing
methylene chloride stripper waste drain.
waste out of the tank and dispose of it properly. CDPHE further ordered that the tank be cleaned, that the
trench drain leading to the underground tank be sealed, and that GMP use a licensed waste management
company to transport all hazardous waste in the future. In response to CDPHE's orders, Teltow hired a
licensed waste management company to pump out the tank, and sealed off the trench drain to the under-
ground tank. However, rather than hire a licensed waste management company to clean out the tank, Tel-
tow ordered subordinate employees to clean out the tank without the benefit of any personal protective
equipment. The employees were exposed to hazardous waste containing methylene chloride, and suffered
from headaches, dizziness, and nausea.
Teltow then devised a new plan for treating GMP's hazardous waste by "evaporating" it into the
atmosphere. Teltow ordered subordinate GMP employees to pour the hazardous waste onto the floor of the
hangar at the end of the work day. Workers would then leave the hangar doors ajar and allow the methyl-
ene-chloride waste to evaporate. Teltow knew that it was illegal to treat the hazardous waste in this man-
ner. When Teltow's "evaporation" method was unsuccessful at treating all of the waste that GMP accu-
mulated, Teltow drilled open the trench drain so that the waste could again flow into the underground tank.
The investigation was conducted by EPA's Criminal Investigation Division, with assistance from
inspectors at the Occupational Safety and Health Administration and CDPHE. The case was prosecuted by
James B. Nelson of the Department of Justice's Environmental Crimes Section.
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EPA Bulletin March 2013 11
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Indictments/Informations (Back to Quick Links)
Colorado Man and His Business Charged with Illegally Discharging Sewage into Reservoir — On
March 20, 2013, JOHN ALBERT PAQUETTE, of Longmont, Colorado, and his company, EAST
POINT, LLC, were charged by information in federal district court for the District of Colorado with
knowingly discharging a pollutant without a permit from a point source into waters of the United States.
According to the information, on June 20, 2012, Paquette and East Point, LLC, knowingly discharged
1,000 gallons of raw sewage from a hose into the Oligarchy Ditch, which flowed into the Union Reservoir,
located in Longmont, Colorado.
If convicted, the company faces not more than five years probation, a fine of at least $5,000 and
not more than $50,000 per day of violation. Paquette, if convicted, faces up to one year in prison and a
fine of at least $2,500 and not more than $25,000 per day of violation.
The case is being investigated by EPA's Criminal Investigation Division. It is being prosecuted by
Assistant U.S. Attorney Suneeta Hazra. The charges contained in the information are allegations, and the
defendants are presumed innocent unless and until proven guilty.
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EPA Pub. 310-N-13-003
EPA Bulletin March 2013 12
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