Loaded Parents Implicate Themselves and College Admissions Scammers Over Phone

William “Rick” Singer (Edge College & Career Network)

At least four Orange County residents, a local fashion icon and his famous actress wife admit to their roles in a federal fraud case involving a Newport Beach college admissions consulting firm, according to court documents.

Based on the transcripts of recorded phone calls in the indictment brought by the U.S. Attorney in Boston, those defendants and other high-powered parents named in the complaint implicate Long Beach’s Donna Heinel, the USC senior associate athletic director who is now facing a federal racketeering conspiracy rap.


The 57-year-old is also facing a career change as she and legendary water polo coach and fellow indictee Jovan Vavic were fired by the university on Tuesday.

Among those Heinel is tied to in the federal indictment is Douglas Hodge, 61, a Laguna Beach resident who is the former CEO of Newport Beach investment management company PIMCO, and Michelle Janavs, 48, the Newport Coast namesake of the Michelle Janavs Foundation charity and a former executive of a large food manufacturer her family used to own.

Donna Heinel (Twitter)

Heinel also plays a key role in the allegations against Full House actress Lori Loughlin and her husband Mossimo Guinnulli, who started the Mossimo clothing line on Balboa Island. He amassed an $800 million fortune largely from partnering with the Target store chain, which dropped Mossimo in 2017.

All the indicted defendants, who face federal wire and mail fraud allegations, are tied in the FBI indictment to William “Rick” Singer, the founder of the for-profit Edge College & Career Network–a.k.a. “The Key”–and the phony Key Worldwide Foundation charity that funneled bribes to the Newport Beach firm. The feds say Singer has agreed to plead guilty to the charges against him and be a cooperating witness for the government.

In a phone call secretly recorded by the FBI, it is alleged that Singer told Guinnulli that Heinel was impressed with a photo the father had included that made it appear his older daughter was a competitive rower when she was not, in fact, a student-athlete, even though she was later admitted to USC as one.

“It’s funny,” Singer is quoted as saying on the call. “Because Donna called me couple weeks ago and says, ‘Hey, uh,’ you know, ‘going forward, can you use the same format you used for [the GIANNULLIS’ older daughter] and [their younger daughter], and the regattas that you put in there, for any girls, going forward, that don’t row crew?’ So it’s funny how– I thought I was just makin’ stuff up.”

Janavs is quoted as saying during a secretly recorded phone conversation with Singer that she fears her younger daughter, who is unknowingly following her older sister in taking an admissions test that will actually be taken by someone else to improve chances for college acceptance, will get wise to the scheme.

“She’s totally different than [my older daughter],” Janavs is claimed to have said. “Like she needs to really think she d– [my older daughter] is like, ‘This test is such bullshit. I don’t really care. I don’t ever want to take it.’ But [my younger daughter] is like actually studying to try and get a 34” on the 1-36 ACT scale.

Other local parents named in the indictment are I-Hin “Joey” Chen, 64, a Newport Beach resident whose Torrance company provides warehousing and related services for the shipping industry, and Laguna Beach’s Robert Flaxman, the 62-year-old founder and CEO of real estate development firm Crown Realty & Development.

One of Singer’s most-telling exchanges was with William E. McGlashan Jr., a Mill Valley resident and senior executive at a global private equity firm. During a secretly recorded phone call, Singer is said to have mentioned that if he could get McGlashan’s son accepted to USC as a kicker or punter on the Trojans football team, his odds of admission would jump 90 percent. Here is the government transcript in the indictment:

SINGER: So, you know, essentially she [Heinel] told me when I get all the paperwork together, and I gotta create this profile pic. So what I’ll probably need, if you guys have any pictures of him playing multiple sports, or something where you can kind of see his face a little bit in action?
McGLASHAN: Umm. Hmm.
CW-1: It would be helpful because I will Photoshop him onto a kicker.
McGLASHAN: (laughs) Okay. Okay. Let me look through what I have. Pretty funny. The way the world works these days is unbelievable.

You’ve got that right, Billy! As FBI agent Laura Smith says of these parents, “Beginning in or about 2011, and continuing through the present, the defendants—principally individuals whose high-school aged children were applying to college—conspired with others to use bribery and other forms of fraud to facilitate their children’s admission to colleges and universities in the District of Massachusetts and elsewhere, including Yale University, Stanford University, the University of Texas, the University of Southern California and the University of California-Los Angeles, among others.”

Transcripts of some of the government-recorded phone calls between Singer and local parents begin after the jump.

Singer is identified in court documents as CW-1 given his cooperating witness status. Here is the section involving the wire and mail fraud charges against Hodge:

400. Defendant DOUGLAS HODGE is a resident of Laguna Beach, California. HODGE is the former CEO of a large investment management company based in Newport Beach, California.
401. As set forth below, HODGE agreed to use bribery to facilitate the admission of two of his children to USC as purported athletic recruits, and sought to enlist CW-1 to secure the admission of a third child to college through bribery as well.
402. In an e-mail to HODGE and his spouse on or about February 4, 2008, CW-1 wrote: “I spoke to my connection at Georgetown and he will work with us. He helped me get two girls in last week.” HODGE responded that his eldest daughter “had a great experience at Georgetown. So, who knows? This may prove the defining piece in the college puzzle.” CW-1 replied, in substance, that HODGE’s daughter had only a 50 percent chance “at best” of getting into Georgetown based on her academic record, but that “there may be an Olympic Sports angle we can use.”
403. HODGE’s daughter’s application to Georgetown, submitted on or about November 4, 2008, indicated, among other things, that she won multiple United States Tennis Association tournaments. In fact, USTA records indicate that HODGE’s daughter never played in a USTA match.
404. On or about December 23, 2008, Georgetown mailed HODGE’s daughter a conditional acceptance letter noting that “[t]he Committee on Admissions has conducted an initial review of your application to the Class of 2013 at the request of Mr. Gordie Ernst, Tennis Coach. I am pleased to report that the Committee has rated your admission as ‘likely.’”
405. HODGE’s eldest daughter did not play tennis at Georgetown.
406. On or about September 28, 2012, HODGE e-mailed his younger daughter’s high school transcripts and class schedule to CW-1 and wrote: “I think this is what you were looking for. Sorry for the delay.”
407. On or about October 15, 2012, CW-1 directed a payment of $50,000 from CW-1’s for-profit business account to a bank account in the name of a private soccer club controlled by Khosroshahin, then the head coach of women’s soccer at USC, and Janke, then an assistant coach of women’s soccer at USC.
408. HODGE’s daughter’s application to USC, submitted on or about December 16, 2012, stated that she was a co-captain of a Japanese national soccer team, and an “All American” midfielder on a prestigious club soccer team in the United States.
409. On or about February 12, 2013, CW-1 directed another $50,000 payment from his for-profit business to the private soccer club controlled by Janke and Khosroshahin.
410. On or about February 13, 2013, Khosroshahin e-mailed Heinel an athletic profile falsely describing HODGE’s daughter as, among other things, a “TOP DRAWER ESTIMATED # 3 RECRUTING CLASS IN NATION,” “All Ex Patriot Japan National Select Team Player,” and a member of the “All National Championship Tournament Team.”
411. Heinel presented HODGE’s daughter to the USC subcommittee for athletic admissions as a purported soccer recruit on or about February 14, 2013. On or about March 26, 2013, USC mailed HODGE’s daughter a formal acceptance letter.
412. Less than two weeks later, on or about April 3, 2013, CW-1 e-mailed HODGE that he “wanted to follow up on next steps for spot since their kids are not that strong.” HODGE responded: “Understood. I will talk with [my son] tomorrow.”
419. On or about January 28, 2015, HODGE’s spouse e-mailed CW-1, with a copy to HODGE, noting that she had not been able to find photos of the son who was applying to USC playing football, but had found photos of his brother playing football. CW-1 forwarded the email to Janke and wrote: “See below—I am sure there is a tennis one too. The boys look alike so I thought a football one would help too?”
420. On or about January 30, 2015, HODGE e-mailed Heinel: “Thanks so much for your time yesterday. We are preparing [my son’s] ‘sports resume’ as you requested and should be ready to send it on to you early next week.” Heinel responded: “Great, looking forward to it…you should concentrate on his primary sport with accolades and achievement, then” add his secondary sport. HODGE forwarded the e-mail chain to CW-1.
421. Later that same day, Janke e-mailed two falsified athletic profiles of HODGE’s son—one relating to football, the other relating to tennis—to CW-1. The football profile included various fabricated football achievements, including “Varsity Football Sophomore – Senior Year,” “Team Captain – Senior Year,” and “NH Independent Schools All-American Selection 2013, 2014.” In fact, records from the HODGE’s son’s school indicate that he did not play football in high school other than during his freshman year. The tennis profile included fabricated or exaggerated tennis achievements, including that, while in high school, HODGE’s son was a member of the First Team Lakes Region League. In fact, while HODGE’s son did play tennis on his high school’s team, the school has no record of his involvement on the First Team Lakes Region League. CW-1 forwarded the profiles to HODGE and wrote: Doug I have provided t[w]o profiles from Laura. Please download and send to Donna [Heinel] and ask her to use whichever one she likes. Obviously we have stretched the truth but this is what is done for all kids. Admissions just needs something to work with to show he is an athlete. They do not follow up after Donna presents. Please confirm receipt and when you send to Donna.
422. On or about February 2, 2015, Janke e-mailed Heinel that HODGE “is on his way to Japan for work so he asked me to send these over to you as he did not have your email on him but wanted to get these to you ASAP.” Attached to the e-mail were the two falsified athletic profiles. Heinel replied with the athletic profile of a different student with a note that said “an example of football.” In a separate e-mail, bearing the subject line “Suggestions,” Heinel provided handwritten edits to the football profile and indicated that the photograph included on the profile should be exchanged for a “better picture” that was “more athletic.”
423. Heinel presented HODGE’s son to the USC subcommittee for athletic admissions as a purported football recruit on or about February 12, 2015.
424. On or about March 17, 2015, Janke e-mailed CW-1 the following: I just got this message from Donna [Heinel]: [HODGE’s son]’s admission packet will be mailed on March 24th. After the the [sic] packet is received please let the father know to send the check directly to me at USC, make out to what we had discussed before. Thank you!
425. CW-1 forwarded the message to HODGE and wrote: Doug one of the folks helping us at USC sent the message below that [your son’s] Admit Packet will be sent on March 24. I will need to take care of the different parties separately, which I will accomplish to finalize all the dealings. Once you receive the Acceptance please let me know so we can move forward financially. HODGE replied, “Fantastic!! Will do.”
426. USC mailed HODGE’s son a formal acceptance letter on or about March 24, 2015. Exactly one week later, HODGE mailed Heinel a $75,000 check payable to the USC “Womens Athletic Board.” On or about April 1, 2015, HODGE wired $125,000 to The Key, and $125,000 to KWF. CW-1, in turn, directed a payment of $50,000 from KWF to a bank account controlled, in part, by Janke in the name of “SC Futbol Academy,” a private soccer team.
427. On or about April 10, 2015, KWF issued a letter to HODGE falsely representing that “no goods or services were exchanged” for his purported contribution of $125,000.
428. HODGE’s son deferred his admission to USC, ultimately matriculating there in 2017. He did not join the football team.
429. On or about August 10, 2018, HODGE called CW-1 to discuss the possibility of pursuing the college recruitment scheme to facilitate his youngest son’s admission to Loyola Marymount University (“LMU”). The following is an excerpt from the call, which was intercepted pursuant to a Court-authorized wiretap.

HODGE: So LMU, when we went down this past the last time– and this is where, you know, this is the [CW-1] magic at work. You sa– I remember you saying well, listen, if you want LMU, and you want to commit to LMU, let me know because, you know, this is one of the schools where you have developed relationships.
CW-1: And we can get it done.
CW-1: Done.
HODGE: Yeah, so– and I know how this works. I you know we, we, we don’t have to talk in code. We know how this works.
CW-1: Right.
HODGE: So if, if, if LMU, I mean, this requires him to commit, like LMU is my first choice. Because once, once you go to bat for him it’s, that’s pretty much a done deal right?
CW-1: Correct, yeah.

430. In a call on or about November 30, 2018, CW-1, at the direction of law enforcement agents, told HODGE that the IRS was conducting an audit of KWF. The following is an excerpt from the call, which was consensually recorded.

CW-1: We had the discussion about us being audited.
CW-1: Now they’ve decided that they are going to make phone calls to all the USC kids’ donations.
HODGE: Okay.
CW-1: So there’s– there’s 25, 30, 35 kids total. I don’t know who they’re going to call and who they’re not but I– you know, what I’ve told them is, you know, there was $200,000 for [your daughter], 250[,000] for [your son], that they both got in, and that we both know they both got in through athletics. [Your daughter] got in even though she wasn’t a– a legit soccer player and [your son] not a legit– I think we did football for [him].
HODGE: Right.
CW-1: But we didn’t go in there. We didn’t even discuss that. What I said to them is that your monies essentially went to our foundation to help fund underserved kids and that’s how we left it. But I think that they’re going to call some of the USC families that we’ve gone [inaudible] the years. So I just wanted you to have a headsup.
HODGE: So with [my daughter]– [my son] I’m fine. I’m complete– and I’m first of all, I will– I– what you just described is exactly–would be my words, okay. So you don’t have to worry. I’m not going to– I’m not– I’m not going off script here. One thing to remember is, I had a conversation. You set me up with this woman, who I think was like the– not– she wasn’t the soccer coach but she was in the athletics department.
CW-1: So it might have been with Donna Heinel that you guys–
HODGE: Yeah.
CW-1: Okay.
HODGE: But we talked on the phone and she said, you know, “Thank you very much,” and I said, “Well, we want to support USC athletics and looking forward to [my daughter],” and, you know, all this–all that stuff. So that conversation sort of pierces that story of, I made a donation into the foundation, because she was like basically, “Well, thank you, Mr. HODGE, for your– I’ll call it 169 support.” We didn’t talk about money. There was no conversation about–there was not dollars discussed on that phone call. But, you know, we’re kind of talking in code here.
CW-1: Right.
HODGE: So that’s out there.
CW-1: Yeah.
HODGE: I don’t know if they talked to her, what she might say, but I– I know what I did, which is I donated to your foundation. That foundation has– its stated mission is to help underserved kids basically get into– you know, through– get through college. And that’s all I’m going to say.

Janavs is a frequent presence on the Orange Coast society circuit. The section of the indictment involving her references Singer (as CW-1) and another cooperating witness, Mark Riddell of the IMG Academy college prep company in Florida, who is identified as CW-2:

379. Defendant MICHELLE JANAVS is a resident of Newport Coast, California. JANAVS is a former executive at a large food manufacturer formerly owned by members of her family.
380. As set forth below, JANAVS participated in both the college entrance exam scheme and the athletic recruitment scheme, including by conspiring to use bribery to facilitate her daughter’s admission to USC as a purported beach volleyball recruit.
381. On or about August 11, 2017, JANAVS forwarded CW-1 correspondence from ACT, Inc. indicating that her daughter had been approved for extended time on the ACT. CW-1 replied: “Awesome news. It works.”
382. On or about August 31, 2017, JANAVS received an e-mail from ACT, Inc. with instructions on how to register her daughter to take the ACT, with extended time, at her high school.  JANAVS forwarded the e-mail to CW-1 and asked, “Do I sent this info/form requested to [my daughter’s high school] or directly to you?” CW-1 responded: “Normally your school then we request the test to move.”
383. On or about October 27, 2017, CW-2 flew from Tampa to Los Angeles. On or about October 28, 2017, JANAVS’ daughter took the ACT at the West Hollywood Test Center, with CW-2 serving as the purported proctor. CW-2 returned to Tampa the following day. JANAVS’ daughter received a score of 32 out of a possible 36 on the exam.
384. On or about October 29, 2017, the day after the test, CW-1 directed a KWF [Key Worldwide Foundation] employee to send an invoice to JANAVS in the amount of $50,000. CW-1 also caused KWF to pay $18,000 to CW-2 and $13,000 to Dvorskiy for helping JANAVS’ daughter and another student cheat on the ACT.
385. On or about November 30, 2017, JANAVS sent a check for $50,000 from her foundation to KWF.
386. In or about the fall of 2018, the falsified ACT scores were included as part of JANAVS’ daughter’s application for admission to USC, and JANAVS provided information to CW-1 for use in facilitating her daughter’s admission to the university as a purported beach volleyball recruit. In fact, while JANAVS’ daughter played volleyball in high school, she did not play competitive beach volleyball.
387. For example, on or about August 24, 2018, CW-1 e-mailed JANAVS to request that she send him “an action volleyball indoor and beach photo of [your daughter] as soon as possible.” Two days later, JANAVS e-mailed CW-1 photos of her daughter playing beach and indoor volleyball.
388. On or about September 4, 2018, CW-1 e-mailed Heinel an athletic profile of JANAVS’ daughter that included two of the photos and falsely described her as the winner of multiple beach volleyball tournaments in California.
389. In a call on or about October 1, 2018, CW-1 told JANAVS that Heinel planned to present her daughter to the USC admissions committee as a beach volleyball player, and explained where to send the bribe payments. The following is an excerpt from the call, which was consensually recorded.

CW-1: So she’s gonna go through on Thursday, so I just want to confirm the process, the next pro– part of the process, which would be soon thereafter I will get a letter from USC stating– like a likely letter– that she has been in– admitted under these conditions, which is doing an NCAA clearinghouse, finishing her semester, blah, blah, blah, and at that point you guys would send a $50,000 check to USC Athletics, in care of Women’s Athletics–
CW-1: –at that point. Are you okay with that?
CW-1: Okay, and–
JANAVS: [inaudible] that’s fine.
CW-1: Okay, and then when she gets her final, final letter, which will happen around March 25th, then you would send the rest of the money. So, I just–
JANAVS: To USC or to you?
CW-1: To our foundation.
JANAVS: Yeah, so the first $50,000 goes to USC?
CW-1: Right, correct.

390. Heinel presented JANAVS’ daughter to the USC subcommittee for athletic admissions as a purported beach volleyball recruit on or about October 3, 2018.
391. On or about October 17, 2018, at the direction of law enforcement agents, CW-1 forwarded to JANAVS a letter noting that her daughter had been conditionally admitted to USC. The letter stated: “Your records indicate that you have the potential to make a significant contribution to the intercollegiate athletic program as well as to the academic life of the university.” JANAVS replied, “Thank you. Let me know about next steps.”
392. On or about October 26, 2018, CW-1, at the direction of law enforcement, emailed JANAVS instructing her to mail a $50,000 check to Heinel payable to the USC Women’s Athletics Fund. JANAVS advised CW-1 that she mailed the check to Heinel later that same day.
393. One month later, on or about November 26, 2018, JANAVS called CW-1 to
discuss plans to engage in the college entrance exam scheme for her younger daughter. The following is an excerpt from the call, which was consensually recorded.

JANAVS: [CW-1], I had a question for you. So I was able to get [my younger daughter] the multiday ACT.
CW-1: Okay, you got her extended time multiple days, got it.
JANAVS: Yes, so I got that, the only thing is h– [my younger daughter] is not like [my older daughter]. I’m not [inaudible] works. She’s not stupid. So if I said to her, “Oh, well, we’re going to take it up at [CW-1]’s,” she’s going to wonder why. How do you do this without telling the kids what you’re doing?
CW-1: Oh, in most cases, Michelle, none of the kids know.
JANAVS: No, I know that.
CW-1: Essentially what happens is they take the test with a proctor like they normally do and w–, and then so they take the test, they leave, and then the proctor looks at what she’s already done and then whatever number that we’re trying to get, that’s what he works to get. So she doesn’t even know.
JANAVS: Right, but how– no, I understand, she won’t even know. But how do you explain [it] to her? Because I got the letter from the school and they said, “You know, you need to take it at the school.” Because remember last time they gave [inaudible] little bit of a hard time? How do you– how do they work around that?
CW-1: So one of the ways you could do it is to say, “Listen, we’re going to take it on the weekend. And we don’t want you to miss any school.” Because it’s difficult when [inaudible] much class time. And we need to take this over a Saturday-Sunday. So we’re going to do [it] up there because they’ll administer the test over multiple days. But the school– but– but– hold– let’s go back. It doesn’t matter about the school at all. The issue is [your daughter]. The school– school wants to be able to give it, but they don’t have to give it. So you don’t really have to say anything. For the school you could say that weekend you guys are going to be up in L.A. and [inaudible].
JANAVS: That’s what we did last time. Yeah, so when– well, [my daughter] is the issue. There’s two issues. Yeah. One is, you know– I mean [my daughter] is more the issue because she’s going to say to me, “You know, well, why am I taking it up there?”
CW-1: And you’re just going to say, “We don’t want you to miss any school so we’re going to do this on a weekend up here because we g– [inaudible] because it’s really easy, it’s convenient, and we can get it done over the weekend, you won’t miss any school.”
JANAVS: So do you– so I would actually have her go Saturday and Sunday to pretend like she’s taking it over multiple days.
CW-1: Well, if you want to do that, because she’s–
JANAVS: She’s smart, she’s going to figure this out. Yeah, she’s going to say to me–she already thinks I’m up to, like, no good.
CW-1: I got it. So let’s, yeah, so that’s what we would have to do is over multiple days.
JANAVS: Okay. So then the other question is, if I want to sign her up– or I’ve already signed her up for February. Or can I sign her up in December and not have it go through [her high school] at all?
CW-1: Well, no matter what it goes through. Because it’s her home school [inaudible] what we have to do is redirect the test to be– to be given at [inaudible] site. So [inaudible] so stick with where you are. We’ll just redirect. She’s already signed up. We just have to redirect the materials to be sent like we did for [your older daughter].
JANAVS: Okay. Okay. Right, I see. Okay. Okay. Okay. Yeah, they’re not stupid either, but whatever, I don’t care. They can’t say anything to me. I mean they’re going to be suspicious that every kid I have does so well somewhere else, but that’s okay. So we’ll, I just didn’t– I just didn’t want to have this conversation with [my younger daughter].
CW-1: No, no, totally get it, yeah. No, I totally get it.
JANAVS: She’s totally different than [my older daughter]. Like she needs to really think she d– [my older daughter] is like, “This test is such bullshit. I don’t really care. I don’t ever want to take it.” But [my younger daughter] is like actually studying to try and get a 34.
CW-1: Got it. Got it.
JANAVS: So it would– it would actually be a great boost to her. And [my older daughter] came to me and she says, “You’re not going to tell [my sister], are you?” I was like, “No.” Weird– weird family dynamics, but every kid is different.
CW-1: Cool.
JANAVS: Okay. Okay, so we’ll just stick with February and now I know we’re just trying to get it done on the weekend. You’ll just go up too. And she doesn’t see you at all.
CW-1: No.
JANAVS: So we’ll just say there’s a proctor. I don’t even have to say anything about
CW-1: Yeah. No, not at all.

394. In a call on or about January 3, 2019, JANAVS discussed the cost of the exam bribery scheme with CW-1. The following is an excerpt from the call, which was consensually recorded.

JANAVS: Yeah, so it helped that you mentioned it to [my daughter]. You could tell, she was like, “Well I should just do it at school.” I’m like, “Oh my god, no.” Yeah, let’s just go ahead and I’ll just come up with something for her. Let’s take it over there. But the thing [is], I need her to do the full thing and take it over two days– like as if she is really doing it. She’s not stupid.
CW-1: No, I got you. She’s, she’s, you know, she’s taking the test anyways on her own [inaudible] as if she is really doing it. We’ll just split it in half. And then [CW 2] will clean it up so we can get the score we need to get, afterwards. So I’ll just tell him he has to do it for two days. And we’ll do half a day, half of that time on Saturday and half the time on Sunday.
JANAVS: Yeah, how much is that still?
CW-1: I think it’s like $50,000.
JANAVS: Yeah, that’s what we did last time. Okay.

395. During the same call, CW-1 told JANAVS that Heinel had been questioned about why JANAVS’ older daughter was on the volleyball recruit list at USC. The following is an excerpt from the call.

CW-1: I got a call from Donna Heinel, at USC.
JANAVS: Uh-huh.
CW-1: And so the sa– ’cause we went through sand volleyball, which we know she’s really not a– you know, I — I couldn’t put her through as a 6-person volleyball, indoor volleyball–
CW-1: –because they’re– they’re so awesome. So the sand volleyball coach was asking Donna– ’cause she saw her list of student athletes that they recruited. So she asked about [your daughter]. And so I doubt it but you may get a call from the staff, at USC sand volleyball.
CW-1: And if you do, you’re ju– they may just ask you, “Is [your daughter] preparing for the fall?” And, of course, you will say–
CW-1: “Yes. And we live in Newport. And w– she’ll play tournaments over the summer.” And then, if they do call you, let me know. And then I will call Donna, to squash this thing.

396. On or about January 14, 2019, JANAVS sent CW-1 the following text message: “Spoke with [my younger daughter]. We are set to take up in LA.” Later that same day, JANAVS spoke with CW-1 about the exam scheme by telephone. The following are two excerpts from the call, which was consensually recorded.

JANAVS: So I have a question for you. I’m trying to figure out how best to deal with [my younger daughter] on this. So [my daughter] has said to me, “I’m gonna get a 34 on this ACT,” or “I’m gonna keep taking it till I get a 34.” And I’m like, “[Daughter], what if you got like a 32 or a 33?” She’s like, “W– no. I would take it till I get a 34.” I don’t know if that’s true, but she’s fucking driving me nuts. But what I don’t want to happen is us to say– she gets a 33 and her go, “I’m gonna take it again.”
CW-1: I gotcha. Oh, I totally get that.
JANAVS: I’m like– you know, I just want this one done. And I don’t know if she’s serious. Because she’s not scoring that well on these.
CW-1: Right.
JANAVS: So I don’t know if she’s serious that she would take it again. I mean, I think a 34 might be a little high. But at the same time, maybe it’s like, screw it, just give her the damn 40– 34, so that we don’t have to worry about her saying, “I’m taking it again.”
CW-1: Totally agree.
CW-1: She may end up with a 35, just because there could be a question here or a question there that sh– I mean, ’cause it’s like missing hardly any questions at all. So it depends on the curve of the day. So, you know. And it may end up– again, it could be a 35, it could be a 34, it could be a 33. It could be within one question. You don’t know, for that day.
JANAVS: I see. Okay. So do you–
CW-1: Because she’s sco– she’s scored against everybody else in the country that’s takin’ the test.
JANAVS: Right. Right, right. So it’s not like a guarantee. But it’ll be a guarantee between a 33 and a 35.
CW-1: Correct.
JANAVS: Okay. And if she gets a 33 and tells me she’s gotta take it again, then you deal with her.
CW-1: I know.
JANAVS: Then she’s your problem.
CW-1: I totally gotcha. So here’s one thing. I’m waiting for [CW-2], who’s our proctor/test-taker. He just had a baby, so I’m waiting to confirm that he can do it on that weekend. So once I get that back, I’ll let you know. But we’re ready to do all the paperwork and all that stuff, but as soon as I know. I’m hoping he’ll tell me in the next couple days.

397. On or about February 5, 2019, JANAVS mailed KWF a check in the amount of $25,000.
398. On or about February 9, 2019, JANAVS’ younger daughter took the ACT at the West Hollywood Test Center. Law enforcement agents conducting surveillance observed Dvorskiy, the test center administrator, arrive at the school at approximately 7:10 a.m. CW-2 arrived two minutes later. At approximately 7:49 a.m., JANAVS and her daughter met Dvorskiy in the front of the building, and then went inside together. JANAVS left the building approximately three minutes later. Agents observed JANAVS return to the test center at approximately 12:41 p.m. JANAVS’ daughter left the building approximately fifteen minutes later and drove away with her mother. CW-2 left the test center approximately two hours later.
399. JANAVS wired $25,000 to a Boston, Massachusetts account in the name of KWF on or about February 12, 2019. JANAVS was unaware that the account had been opened by CW-1 at the direction of federal agents.

Here is the portion of the indictment concerning Giannulli and Loughlin:

194. Defendants MOSSIMO GIANNULLI and LORI LOUGHLIN (collectively, “the GIANNULLIS”), a married couple, are residents of Los Angeles, California. GIANNULLI is a fashion designer. LOUGHLIN is an actress.
195. As set forth below, the GIANNULLIS agreed to a pay bribes totaling $500,000 in exchange for having their two daughters designated as recruits to the USC crew team—despite the fact that they did not participate in crew—thereby facilitating their admission to USC.
196. On or about April 22, 2016, GIANNULLI, copying LOUGHLIN, sent an e-mail to CW-1, noting:

We just met with [our older daughter’s] college counselor this am. I’d like to maybe sit with you after your session with the girls as I have some concerns and want to fully understand the game plan and make sure we have a roadmap for success as it relates to [our daughter] and getting her into a school other than ASU!

197. CW-1 responded, “If you want [U]SC I have the game plan ready to go into motion. Call me to discuss.”
198. In an e-mail on or about July 24, 2016, CW-1 advised GIANNULLI that his older daughter’s academic qualifications were at or just below the “low end” of USC’s admission standards. Thereafter, the GIANNULLIS agreed with CW-1 to use bribes to facilitate her admission to USC as a recruited crew coxswain, even though she did not row competitively or otherwise participate in crew.
199. On or about September 7, 2016, GIANNULLI sent CW-1 an e-mail attaching a photograph of his older daughter on an ergometer.
200. Heinel presented the GIANNULLIS’ daughter to the USC subcommittee for athletic admissions as a purported crew recruit on October 27, 2016. At the meeting, the subcommittee approved her conditional admission to the university.
201. Two days later, on or about October 29, 2016, CW-1 e-mailed GIANNULLI,
“Please send $50K payment to the person below[:] Donna Heinel, Senior Women[’]s Associate Athletic Director[,] c/o of USC Athletics[.]”
202. On or about November 1, 2016, GIANNULLI replied, “I told biz mgr to Fed Ex today.” GIANNULLI also asked CW-1 whether it was permissible to discuss his daughter’s admission with the then-USC Athletic Director, with whom he was acquainted. GIANNULLI wrote: “BTW, headed to Augusta in 2 weeks with [the USC Athletic Director]. I was planning on saying nothing? Agree or okay to mention anything?” CW-1 replied: “Best to keep [the USC Athletic Director] out of it. When I met with him a year ago about [your daughter] he felt you were good for a million plus.” GIANNULLI responded, “HAH!!”
203. On or about November 28, 2016, CW-1 sent GIANNULLI confirmation that his daughter had been provisionally admitted to USC based upon “records [that] indicate that you have the potential to make a significant contribution to the intercollegiate athletic program . . . .”
CW-1 wrote: “FYI attached is the letter you can hold on to. As long as [your daughter] doe[s] what she is doing all is good.”
204. On or about March 23, 2017, USC mailed the GIANNULLIS’ daughter her
formal acceptance letter. One week later, Masera sent the GIANNULLIS an invoice from KWF for $200,000, and wrote, “Thank you for your pledge to The Key Worldwide Foundation. Your pledge is now due . . . . Our receipt letter will go out to you upon full payment.” GIANNULLI responded, “Again thanks for all. We are currently on holiday in the Bahamas but will gladly handle this when home next week.”
205. On or about April 10, 2017, GIANNULLI wired $200,000 to KWF. The following day, an employee of CW-1 sent the GIANNULLIS a receipt from KWF falsely indicating that “no goods or services were exchanged” for the purported donation.
206. On or about April 10, 2017, GIANNULLI copied LOUGHLIN on an e-mail to CW-1 bearing the subject line, “Trojan happiness.” He wrote: “I wanted to thank you again for your great work with [our older daughter], she is very excited and both Lori and I are very appreciative of your efforts and end result!” CW-1 replied, “With [your younger daughter] please let me know if there is a similar need anywhere so we do not lose a spot.” GIANNULLI responded, “Yes [our younger daughter] as well,” and LOUGHLIN added, “Yes USC for [our younger daughter]!” CW-1 replied, “So work to acquire [U]SC? As soon as the semester is over I will need a transcript and test scores.”
207. On or about July 14, 2017, CW-1 e-mailed Janke directing her to prepare a crew profile for the GIANNULLIS’ younger daughter. Janke responded: “Ok sounds good. Please send me the pertinent information and I will get started.”
208. On or about July 16, 2017, CW-1 e-mailed the GIANNULLIS requesting
information for the crew profile. CW-1 indicated that the profile would present their younger daughter, falsely, as a crew coxswain for the L.A. Marina Club team, and requested that the GIANNULLIS send an “Action Picture.” Four days later, CW-1 sent the GIANNULLIS a second request, noting, “If we want USC I will need a transcript, test scores and picture on the ERG.” LOUGHLIN, copying GIANNULLI, replied later that day, “Moss will get this done. We are back in town on Monday.”
209. On or about July 28, 2017, GIANNULLI, copying LOUGHLIN, e-mailed CW-1 a photograph of their younger daughter on an ergometer.
210. Heinel presented the GIANNULLIS’ younger daughter to the USC subcommittee for athletic admissions on or about November 2, 2017. At the meeting, the subcommittee approved her conditional admission to the university.
211. Less than two weeks later, on or about November 16, 2017, CW-1 sent the
GIANNULLIS an e-mail bearing the subject line, “CONGRATULATIONS!!!” with their younger daughter’s conditional acceptance letter attached. LOUGHLIN responded, “This is wonderful news! [High-Five Emoji].” CW-1 replied: “Please continue to keep hush hush till March.” LOUGHLIN responded: “Yes of course.”
212. Approximately two weeks later, on or about November 29, 2017, CW-1 directed the GIANNULLIS to “send a 50K check to USC and the address is below. Additionally the rest of the 200k will be paid to our foundation a 501 3C [sic] after [your younger daughter] receives his [sic] final letter in March.” GIANNULLI, copying LOUGHLIN, responded, “Will get this handled this week.” The next day, GIANNULLI directed his business manager to send a $50,000 check to Heinel.
213. CW-1 has advised investigators that, in or about late 2017, a guidance counselor from the high school attended by GIANNULLIS’ daughters inquired of the younger daughter about her sister’s athletic recruitment to USC. According to CW-1, the counselor did not believe that either of the GIANNULLIS’ daughters participated in crew, and was concerned that their applications may have contained misleading information.
214. On or about December 12, 2017, LOUGHLIN e-mailed CW-1, copying GIANNULLI and their younger daughter, to request guidance on how to complete the formal USC application, in the wake of her daughter’s provisional acceptance as a recruited athlete.
LOUGHLIN wrote: “[Our younger daughter] has not submitted all her colleges [sic] apps and is confused on how to do so. I want to make sure she gets those in as I don’t want to call any attention to [her] with our little friend at [her high school]. Can you tell us how to proceed?”
CW-1 responded by directing an employee to submit the applications on behalf of the GIANNULLIS’ younger daughter.
215. On or about February 6, 2018, GIANNULLI wired $200,000 to one of the KWF charitable accounts. On or about February 7, 2018, an employee of CW-1 sent the GIANNULLIS a receipt from KWF falsely indicating that “no goods or services were exchanged” for the purported donation.
216. On or about March 23, 2018, USC mailed the GIANNULLIS’ younger daughter her formal acceptance letter.
217. Shortly thereafter, on or about April 12, 2018, the high school counselor e-mailed GIANNULLI memorializing an encounter between the two men earlier that day: I wanted to provide you with an update on the status of [your younger daughter’s] admission offer to USC. First and foremost, they have no intention of rescinding [her] admission and were surprised to hear that was even a concern for you and your family. You can verify that with [the USC senior assistant director of admissions] . . . if you would like. I also shared with [the USC senior assistant director of admission] that you had visited this morning and affirmed for me that [your younger daughter] is truly a coxswain.
218. The same day, Heinel left CW-1 the following voicemail message: I just want to make sure that, you know, I don’t want the — the parents getting angry and creating any type of disturbance at the school. I just want to make sure those students . . . if questioned at the school that they respond in a[n] appropriate way that they are, walk-on candidates for their respective sports. They’re looking forward to trying out for the team and making the team when they get here. OK? That’s what I just want to make sure of. [Inaudible.] So I just don’t want anybody going into . . . [the GIANNULLIS’ daughter’ high school], you know, yelling at counselors. That’ll shut everything — that’ll shut everything down.
219. In a call with GIANNULLI on or about October 25, 2018, CW-1, acting at the direction of law enforcement agents, told GIANNULLI that the IRS was auditing KWF. The following is an excerpt from the call, which was consensually recorded:

CW-1: I’m calling ’cause I just want to make sure you’re– give you a heads-up that– so my foundation is being audited–
CW-1: –which, as you know, is normal.
CW-1: And so they’re looking at all the payments. So they– they asked me about your 2 payments of 200,000.
CW-1: And, of course, I’m not gonna say anything about your payments going to Donna Heinel at USC to get the girls into USC, through crew. So–
CW-1: –that’s for sure.
CW-1: But what’s funny– It’s funny. Because Donna called me couple weeks ago and says, “Hey, uh,” you know, “going forward, can you use the same format you used for [the GIANNULLIS’ older daughter] and [their younger daughter], and the regattas that you put in there, for any girls, going forward, that don’t row crew?” So it’s funny how– I thought I was just makin’ stuff up.
GIANNULLI: Uh, right. Uh–
CW-1: But– but they loved it, love–
GIANNULLI: Uh, right. Perfect.
CW-1: So I just want to make sure out stories are the same, because–
CW-1: –and th– and that your $400K was paid to our foundation to help underserved kids.
GIANNULLI: Uh, perfect.
CW-1: Okay? So I just want to make sure that we’re on the same page, in case–
CW-1: Who knows if they’ll call or they don’t?
GIANNULLI: Perfect. Got it.

220. Likewise, in a call on or about November 29, 2018, CW-1, acting at the direction of law enforcement agents, told LOUGHLIN that the audit of KWF was focused on payments related to students who had been admitted to USC, including her daughters. The following is an excerpt from the call, which was consensually recorded.

CW-1: The IRS audits foun– large foundations and we have so much money in our foundation and we give away so much money they’re– they want to– you know, they’re always worried about things going on in foundations.
CW-1: So what I– what I wa– I told Moss already and I wanted to make sure that you knew, as well, if they happened to call you, is that nothing has been said about the girls, your donations helping the girls get into USC to do–
CW-1: –crew even though they didn’t do crew. So nothing like that has been ever mentioned.
LOUGHLIN: [inaudible]
CW-1: If you ever– ever were to say anything.
LOUGHLIN: So we– so we just– so we just have to say we made a donation to your foundation and that’s it, end of story.
CW-1: That is correct.
CW-1: Terrific.
CW-1: I just wanted to make sure I touched base because I didn’t want you–
CW-1: –to all of a sudden what– like what’s this call coming from.
LOUGHLIN: Okay, yeah. Okay. Totally. All right. So– so that’s it. So it’s– it’s the IRS. It’s not anyone from USC, it’s the IRS.
CW-1: That is correct.
LOUGHLIN: Okay. Very good.

Here is the section of the indictment involving Chen:

77. Defendant I-HSIN “JOEY” CHEN is a resident of Newport Beach, California. CHEN operates a Torrance, California-based provider of warehousing and related services for the shipping industry.
78. As set forth below, in or about April 2018, CHEN paid $75,000 to CW-1’s for-profit entity, The Key, in exchange for which CW-1 arranged to have CW-2 purport to proctor CHEN’s son’s ACT, and correct his answers. As noted above, CHEN’s son and the [defendants Marcia and Gregory] ABBOTTS’ daughter both took the exam on the same day at the West Hollywood Test Center.
79. On or about April 16, 2018, CHEN paid CW-1 $75,000 to participate in the cheating scheme. The money was deposited into The Key’s bank account. CW-1 has advised law enforcement agents that he agreed to provide CHEN with an invoice falsely indicating that the payment was for “consulting” services for CHEN’s business.
80. CHEN’s son scored a 33 out of a possible 36 on the ACT exam.
81. In a call on or about October 23, 2018, CW-1, acting at the direction of law enforcement agents, told CHEN that CW-1’s charitable foundation was being audited by the IRS. The following is an excerpt from the conversation, which was consensually recorded.

CW-1: And so they’re looking at all the payments that have gone into our foundation.
CHEN: Uh-huh.
CW-1: So they asked about your payment, which was for [your son], you know, taking the test that we did for him at [the West Hollywood Test Center], with [CW-2] –
CHEN: Yeah.
CW-1: And I’ve said that your payment of $75,000–
CHEN: Uh-huh.
CW-1: –went to our foundation to help underserved kids.
CHEN: Uh-huh.
CW-1: Okay?
CHEN: Uh-huh.

82. Shortly after that call, CHEN called CW-1 back and said, in substance, that the description on the invoice he had received from CW-1 said “consulting service.” CHEN asked, “[W]hat should I say [if the IRS asks]– consulting service or foundation?” CW-1 replied, “consulting services for the foundation.” CHEN responded, “Okay.”
83. In a call on or about February 21, 2019, CW-1, acting at the direction of law enforcement agents, told CHEN that the IRS audit had been completed. The following is an excerpt from the conversation, which was consensually recorded.

CW-1: I wanted to call you ’cause I called you before about our audit–
CHEN: Uh-huh.
CW-1: –and I wanted to let you know that our audit is over.
CHEN: Uh-huh.
CW-1: We’re all okay. And we are okay because, so you, you’re not, no issues with you. So nobody will be contacting you, okay?
CHEN: Okay.
CW-1: Because your– the payment that you made, we created a fake consulting invoice that you paid that, instead of making a donation to our foundation.
CHEN: Uh-huh.
CW-1: So there was no link, for the audit in our foundation, because we– you paid the $75,000 to my for-profit company–
CHEN: Uh-huh
CW-1: –with a fake, with a fake consulting invoice. So that’s– that’s why we’re clear.
CHEN: Oh-huh, okay.
CW-1: And then, the other thing is, they asked a question about [CW-2], who took the test for [your son], and Igor, who was the site coordinator, how come I paid them from the foundation at the same time that [your son] was taking the test–
CHEN: Uh-huh.
CW-1: –and since you paid the for-profit company the $75,000, there was no payment for the– as a donation.
CHEN: Uh-huh.
CW-1: And I think that we are past that. So that we both agree that [CW-2] took the test for [your son], right?
CHEN: Yeah.
CW-1: And so everything should be fine so I just wanted to make sure that you’re okay to know that the audit is over, and we should be in good shape.
CHEN: Oh, okay, sounds good.

Here is the portion of the indictment concerning Flaxman:

508. Defendant ROBERT FLAXMAN is a resident of Beverly Hills, California.
FLAXMAN is the president and CEO of a Los Angeles-based real estate development firm.
509. As set forth below, in or about 2016, FLAXMAN participated in both the college recruitment scheme and the college entrance exam scheme.
510. On or about October 25, 2015, CW-1 e-mailed FLAXMAN’s son’s ACT scores and transcript to Martin Fox, who forwarded the materials to a varsity coach at the University of San Diego (“USD”). On or about October 26, 2015, CW-1 e-mailed FLAXMAN that he “spoke to USD and they received [your son’s] info. They are interested in helping.”
511. On or about November 2, 2015, FLAXMAN e-mailed CW-1 asking for an update on the status of his son’s admission to USD. CW-1 replied: “The coach I am working with has not gotten his scheduled appointment with Admissions for all of his recruitable athletes. He is on board to help and has [your son’s] materials. I am sure I will receive a call on next steps soon.” On or about November 12, 2015, a USD admissions counselor e-mailed the varsity coach a memorandum giving the coach approval to sign FLAXMAN’s son to the coach’s team.
512. On or about November 16, 2015, CW-1 e-mailed FLAXMAN and his son. The subject line of the e-mail was: “Here is what I came up with that touches on a lot of who you are and what I put on your application.” The essay, and the application ultimately submitted to USD, referenced FLAXMAN’s son’s purported volunteer work as the manager of an elite youth athletic team. Prior essay drafts contained no references to that sport.
513. USD formally admitted FLAXMAN’s son on or about March 7, 2016.
514. On or about April 22, 2016, a KWF employee e-mailed FLAXMAN an invoice in the amount of $250,000. The cover e-mail described the invoice as a “courtesy reminder of the pledge made to [KWF].” On or about May 9, 2016, the KWF employee e-mailed FLAXMAN again: “Hi Bob, We have some obligations that we must meet. When can we count on your payment?” FLAXMAN replied that he “was supposed to receive [a] revised request that included 501(c)3 info for tax purposes. I would like to make two payments. One now and one end of June.”
515. FLAXMAN’s company wired two payments of $125,000 each to KWF on or about May 13, 2016 and June 23, 2016.
516. On or about June 6, 2016, CW-1 caused KWF to issue a payment of $100,000 to Fox. Fox advised CW-1 that he, in turn, paid the USD coach for facilitating FLAXMAN’s son’s admission.
517. In or about April 2016, FLAXMAN’s daughter took the ACT and received a score of 20 out of a possible 36. On or about September 12, 2016, FLAXMAN e-mailed CW-1 that his daughter took the “ACT this weekend and thought she did better than the last time. She actually finished the exam.” FLAXMAN’s daughter received a score of 24 on the September test.
518. On or about October 4, 2016, CW-1 e-mailed FLAXMAN that his contact at ACT “has the paperwork and will put [your daughter] into [the Houston Test Center] for Oct.” FLAXMAN replied: “Ok. I will need details soon. Address. Who and where to check in and what instructions we need to give [my daughter] to use at the test.” On or about October 6, 2016, CW-1 e-mailed FLAXMAN the address of the Houston Test Center and contact information for Niki Williams, the test center administrator.
519. On or about October 15, 2016, CW-1 directed a KWF employee to send invoices to FLAXMAN and another client in the amount of $75,000 each. CW-1 further instructed the employee to send $50,000 to Fox and $20,000 to CW-2. CW-1 has advised law enforcement agents that the payments were for Fox’s facilitation of CW-1’s relationship with Williams, as well as for CW-2’s purported proctoring of the exam for FLAXMAN’s daughter and the child of CW-1’s other client.
520. On or about October 20, 2016, FLAXMAN’s company wired $75,000 to KWF. On or about October 21, 2016, a KWF employee sent FLAXMAN a letter falsely attesting that “no goods or services were exchanged” for the purported contribution.
521. CW-2 flew from Tampa to Houston on or about October 21, 2016. On or about October 22, 2016, FLAXMAN’s daughter and the child of another client of CW-1 both took the ACT at the Houston Test Center. CW-2 has advised investigators that he assisted FLAXMAN’s daughter and the other student to answer questions on the exam, and instructed them to answer different questions incorrectly so that they did not have the same incorrect answers on their tests, and the ACT would therefore not suspect cheating. CW-2 returned to Tampa the next day.
522. FLAXMAN’s daughter received a score of 28 on the ACT exam.
523. On or about October 23, 2018, CW-1 called FLAXMAN at the direction of law enforcement agents and told him that KWF was being audited by the IRS. The following is an excerpt from the call, which was consensually recorded.

CW-1: Okay– so our– so our books show there was a $250,000 payment for [your son’s] side door into USD, through [the USD varsity coach] and [the varsity sport]–
CW-1: –and there was a 75K payment for[CW-2] to take–
CW-1: –the standardized testing, SAT, ACT, with [your daughter].
CW-1: Okay. So we’re both on the same page.
FLAXMAN: An-an-and the– the reason for the payments is what?
CW-1: The reason for the payments were to, essentially– We won’t say that it went to pay for [your son] to get into USD. We’ll say that the payments were made to our foundation to help kids– underserved kids.
FLAXMAN: Okay. That’s fine.

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