Jeffrey Siegmeister Indictment

Case 3:21-cr-00016-MMH-JBT Document 1 Filed 02/24/21 Page 1 of 33 PageID 1
FILED IN OPEN COURT

~. :Lif. oU, :LI
CLERK. U. S. DISTRICT COURT
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
MIDDLE DISTRICT OF FLORIDA JACKSONVILLE, FLORIDA
JACKSONVILLE DIVISION
UNITED STATES OF AMERICA
V. CASE NO. 3:21-cr- I (p-1'\M ~ - "YJ3T

18 U.S.C. § 371
18 U.S.C. § 1951
JEFFREY ALAN SIEGMEISTER 18 U.S.C. § 1952
MARION MICHAEL O'STEEN 31 U.S.C. § 5331
18 U.S.C. § 666
18 U.S.C. § 1343
26 U.S.C. § 7206
INDICTMENT
The Grand Jury charges:
COUNT ONE
(Conspiracy to Use Facility of Commerce for Unlawful Activity)
A. Introduction
At all times material to this Indictment:
1. JEFFREY ALAN SIEGMEISTER ("SIEGMEISTER") was a
resident of the Middle District of Florida who practiced law in the Middle
District of Florida and elsewhere and was a licensed member of the Florida Bar.
From on or about January 16, 2013, through on or about December 19, 2019,
SIEGMEISTER served as the elected State Attorney for the Third Judicial
Circuit of Florida ("the State Attorney"). In his position as the State Attorney,
SIEGMEISTER had the authority to perform official acts, that is, to bring,
reduce, and dismiss criminal charges, for the State Attorney's Office for the
Third Judicial Circuit of Florida ("the State Attorney's Office"). Prior to
becoming the State Attorney, SIEGMEISTER was a private attorney in private
practice in Lake City, Florida.
2. MARION MICHAEL O'STEEN ("O'STEEN") practiced law in
the Middle District of Florida and elsewhere and was a licensed member of the
Florida Bar. O'STEEN maintained a law office in Dixie County, Florida.
3. The State Attorney's Office was an agency of the State of Florida,
covering counties in the Middle District of Florida, and elsewhere, including
Columbia, Dixie, Hamilton, Lafayette, Madison, Suwannee, and Taylor
Counties. The State Attorney's Office received annual benefits in excess of
$10,000 under a Federal program involving a grant, contract, subsidy, loan, and
other form of Federal assistance.
4. From at least as early as on or about June 12, 2017, and continuing
through at least on or about April 16, 2018, O'STEEN represented an
individual, "Client A," with respect to a criminal case in which Client A was
charged with attempted first degree murder, arson, possession of a firebomb,
and violation of domestic violence injunction, in the Circuit Court of the Third
Judicial Circuit, in and for Columbia County, Florida, in the Middle District of
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Florida.
5. From at least as early as on or about February 26, 2018, and
continuing through at least on or about September 12, 2018, O'STEEN
represented an individual, "Client B," with respect to a criminal case in which
Client B was charged with keeping a gambling house, in the Circuit Court of
the Third Judicial Circuit, in and for Columbia County, Florida, in the Middle
District of Florida.
6. From at least as early as on or about January 23, 2019, and
continuing through at least on or about July 15, 2019, O'STEEN represented
an individual, "Client C," with respect to a criminal case in which Client C was
charged with battery and trespass after warning, in the Circuit Court of the
Third Judicial Circuit, in and for Dixie County, Florida.
B. The Conspiracy
7. From an unknown date but at least in or around November 2017,
and continuing through on or about May 16, 2019, in the Middle District of
Florida and elsewhere, the defendants,
JEFFREY ALAN SIEGMEISTER

and
MARION MICHAEL O'STEEN,
did knowingly and willfully combine, conspire, confederate, and agree with one
another and others, both known and unknown to the Grand Jury, to use a
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facility in interstate and foreign commerce, namely a telephone and wire, to
promote, manage, establish, carry on, and facilitate the promotion,
management, establishment, and carrying on of an unlawful activity, that is,
bribery, in violation of Florida Statute§ 838.015; and extortion, in violation of
Florida Statute § 836.05, and to perform and attempt to perform an act to
promote, manage, establish and carry on, and to facilitate the promotion,
management, establishment and carrying on of the above unlawful activity, in
violation of 18 U.S.C. § 1952(a)(3).
C. Manner and Means of the Conspiracy
8. The manner and means by which the conspirators carried out the
conspiracy included, among other things:
a. It was part of the conspiracy that O'STEEN would and did
request official acts from SIEGMEISTER in his official capacity as the State
Attorney, to include favorable disposition of charges filed against criminal
defendants O'STEEN represented.
b. It was further part of the conspiracy that SIEGMEISTER
would and did use his position as the State Attorney to solicit, accept, and agree
to accept, bribes in return for the favorable disposition of criminal cases
c. It was further part of the conspiracy that SIEGMEISTER
would and did request and solicit O'STEEN to purchase a bull from
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SIEGMEISTER's herd of Florida Braford bulls m exchange for
SIEGMEISTER's favorable disposition of criminal charges against O'STEEN's
clients upon O'STEEN's request.
d. It was further part of the conspiracy that SIEGMEISTER
would and did solicit campaign contributions from O'STEEN and others in
exchange for the specific official action of favorable disposition of charges filed
against O'STEEN's clients.
e. It was further part of the conspiracy that SIEGMEISTER
would and did agree with O'STEEN to delay resolving cases in order to enable
O'STEEN to obtain additional "fees" from at least one of O'STEEN's clients.
f. It was a further part of the conspiracy that the conspirators
would and did perform acts and make statements to hide and conceal, and cause
to be hidden and concealed, the purposes of the conspiracy and the acts
committed in furtherance thereof.
D. Overt Acts
9. In furtherance of the conspiracy, the defendants committed the
following overt acts in the Middle District of Florida and elsewhere:
a. In or around June 2017, O'STEEN was retained to
represent Client A, who was charged by the State Attorney's Office with
attempted first degree murder, arson, possession of a firebomb, and violation of
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domestic violence injunction.
b. On or about November 8, 2017, at approximately 2:51 p.m.,
O'STEEN sent a text message to SIEGMEISTER in furtherance of his request
for leniency for O'STEEN's client, Client A, claiming that the victim did not
want to seek prison time for Client A.
c. On or about November 9, 2017, at approximately 10:48
a.m., SIEGMEISTER replied with a text message to O'STEEN that said,
"When Are you and [V.] and [S.] and [M.] and everybody else going to buy one
of my registered bulls?"
d. On or about December 6, 2017, at approximately 10:48
a.m., O'STEEN sent a text message to SIEGMEISTER with a photograph of
an email from SIEGMEISTER's subordinate Assistant State Attorney to
O'STEEN offering a five-year prison plea deal for O'STEEN's client, Client A.
e. On or about December 6, 2017, at approximately 11:09
a.m., SIEGMEISTER replied with a text message to O'STEEN that read, "I'm
driving but I'll deal with that I'm going to Lake City now."
f. On or about April 16, 2018, SIEGMEISTER and
O'STEEN appeared in the Circuit Court of the Third Judicial Circuit, in and
for Columbia County, Florida, for Client A's case. During that court
appearance, Client A pleaded no contest to the charges of arson, possession of
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a firebomb, and violation of domestic violence injunction, for which
SIEGMEISTER and O'STEEN negotiated a plea that included the state
dismissing the attempted first degree murder charge and resulted in Client A
being sentenced to serve 13 months in the Florida Department of Corrections,
followed by eight years of probation.
g. On or about April 16, 2018, at approximately 5:40 p.m.,
SIEGMEISTER sent O'STEEN a text message with four photographs of
SIEGMEISTER's bulls.
h. On or about February 26, 2018, O'STEEN was retained to
represent Client B, who had been charged by the State Attorney's Office with
keeping a gambling house, a felony offense.
1. On or about August 14, 2018, C.L., a legal assistant from
O'STEEN's law firm, sent Client B an email at O'STEEN's direction that said,
"Michael wanted me to follow up to advise he has set up a meeting with Jeff
[SIEGMEISTER], the State's Attorney for this Friday. If you are wanting a
different result about this issue to go the other way you & Michael discussed
then he needs to know you are serious about what it takes to do so before he
goes to that meeting."
J. On or about August 16, 2018, at approximately 12:29 p.m.,
SIEGMEISTER sent a text message to O'STEEN that said, "We still on for
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tomorrow? If yes, meet me at the Brown lantern at 11 :30 or so. After lunch I'll
drive you out to my farm and show you my bulls and cows. I'll take you back
to your vehicle when we're done."
k. On or about August 16, 2018, O'STEEN asked Client B,
during a recorded telephone call, if, with regard to his criminal case pending
before the State Attorney's Office, Client B could "come up with the entire
$30,000 by next week." O'STEEN also asked Client B to meet with O'STEEN
before O'STEEN met with SIEGMEISTER "so we can make, I want, I want
ah look at you so we're very clear on what I'm gonna go propose."
I. On or about August 17, 2018, at approximately 11:35 a.m.,
O'STEEN told Client B, during a recorded in-person meeting, "So you're
saying, for example, if I gave you a number of $60,000, and I make yours go
away completely, and you're out of here, handle that without any agreement,
you're after a number? I don't know if it'll fly or not," and "So you're saying
you can probably come up with more than 30 if I can make yours go away
without an agreement, is that what you are telling me?"
m. On or about August 17, 2018, at approximately 1:19 p.m.,
SIEGMEISTER texted O'STEEN, "Meet me at Walmart."
n. On or about August 17, 2018, at approximately 3:02 p.m.,
after meeting with SIEGMEISTER in Live Oak, Florida, O'STEEN told Client
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B during a recorded telephone conversation, "I can make everything go away
all, your brothers, the other two nolle pros with you sign an agreement, pay their
cost of investigation, you leave, you will not have to report but one time, uh,
ah, I need, I need $75,000 and everything goes away and you pay the money.
Ah you got to sign this agreement and agree to forfeit what they seized at the
jail, they get to keep that. That's the deal. And we got to do this by Tuesday at
5 o'clock to get this done."
o. On or about August 21, 2018, at approximately 1:47 p.m.,
O'STEEN sent SIEGMEISTER a text message that said, "Send me deferred
pros agreement please."
p. On or about August 21, 2018, at approximately 1:50 p.m.,
SIEGMEISTER sent O'STEEN a text message that said, "I haven't done it yet.
You told me you were waiting on your client and Mr Green. I will do it if we
have a deal. I'll call judge [J] and advise it's been sent to pti [pre-trial
intervention] if we have an agreement. It will probably be tomorrow before I
can send it."
q. On or about August 21, 2018, at approximately 1:58 p.m.,
SIEGMEISTER sent O'STEEN a text message that said, "Does that mean you
have your money?"
r. On or about August 23, 2018, Client B delivered $30,000
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cash to O'STEEN at a car dealership in Columbia County, Florida.
s. On or about August 27, 2018, at approximately 10:22 a.m.,
O'STEEN sent a text message to SIEGMEISTER that said, "When will I have
pti agreement on [Client B]? He is ready to leave for cali."
t. On or about September 4, 2018, Client B delivered another
$30,000 cash to O'STEEN at O'STEEN's law office in Dixie County, Florida.
u. On or about September 4, 2018, at approximately 12:05
p.m., SIEGMEISTER sent O'STEEN a text message that said, "You still on
for next Wednesday? Should've charged you triple based on your windfall lol."
v. On or about September 4, 2018, at approximately 12:07
p.m., SIEGMEISTER sent O'STEEN a text message that said, "Hey, my wife
works for rep [h.] in the panhandle and has been tasked with raising 2500 for
the local Republican Party so they can get matching funds. Want to help me
raise it so I don't have to do some event. I was going to ask [V.] as well. I didn't
think it was that much. Let me know. Call me."
w. On or about September 4, 2018, at approximately 4: 17 p.m.,
SIEGMEISTER sent a text message to O'STEEN that said, "So. You get what
you want and make a mint and I'm persona non grada [sic]."
x. On or about September 12, 2018, SIEGMEISTER sold
O'STEEN and O'STEEN's father a bull for $4,000.
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y. Approximately four days later, on or about September 16,
2018, O'STEEN sold the same bull to a farmer for $3,500.
z. On or about September 18, 2018, at approximately 12:58
p.m., SIEGMEISTER sent a text message to O'STEEN that said, "Did you
mail that$? My wife is freaking out because Thursday is deadline. Our mail
hasn't run today yet."
aa. In or around January 2019, O'STEEN was retained to
represent Client C, who had been charged by the State Attorney's Office with
battery and trespass after warning.
bb. On or about January 30, 2019, at approximately 5:24 p.m.,
SIEGMEISTER sent a message to O'STEEN regarding Client C's criminal
case, that said, in part, "Tell [H.] and [D.] [friends of Client C] hi. Tell them
they're welcome for the PTI on the guy [Client C] who beat some old man on
video. It's already been approved. They shouldn't have any complaints."
cc. Despite a subordinate Assistant State Attorney advising her
boss, SIEGMEISTER, that the victims did not want Client C to get PTI [pre-
trial intervention], on or about March 11, 2019, at approximately 5:38 p.m.,
SIEGMEISTER texted O'STEEN, "The PTI is approved."
dd. On or about March 11, 2019, at approximately 5:39 p.m.,
SIEGMEISTER texted O'STEEN, "FYI I'm raising money and getting
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petitions again. Call me or text me when is a good time to come down and catch
up with you and the crew."
ee. On or about March 13, 2019, at approximately 2:33 p.m.,
SIEGMEISTER sent a text message to O'STEEN that said, "Let me know if
you're serious about my bull."
ff. On or about March 22, 2019, at approximately 2:44 p.m.,
SIEGMEISTER sent a text message to O'STEEN that said, "By the way, that
PTI is causing serious heartburn. That mans wife is yelling, screaming, calling
the press, the AG etc. And no, I'm not revoking offer of PTI for [D.]'s sisters
boyfriend [Client C]. Just FYI."
All in violation of 18 U.S.C. § 371.
COUNTTWO
( Conspiracy to Interfere with Commerce by Extortion)
A. Introduction
1. Paragraphs 1 through 6 of Count One of this Indictment are
realleged and reincorporated as if fully set forth herein.
B. Charge
2. From an unknown date but at least as early as on or about August
9, 2018, and continuing through on or about May 16, 2019, in the Middle
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District of Florida and elsewhere, defendants,

and
did knowingly combine, conspire, confederate, and agree with each other and
others, both known and unknown to the Grand Jury, to obstruct, delay, and
affect in any way and degree commerce and the movement of articles and
commodities in commerce by extortion, as such terms are defined in 18 U.S.C.
§ 1951, that is, the defendants, acting in concert with one another, obtained
property not due defendants from Client B, with Client B's consent, through the
wrongful use of fear of economic harm and under color of official right.
All in violation of 18 U.S.C. § 1951(a).
COUNTTHREE
(Interference with Commerce by Extortion)
A. Introduction
1. Paragraphs 1 through 6 of Count One of this Indictment are
realleged and reincorporated as if fully set forth herein.
B. Charge
2. From an unknown date but at least as early as on or about August
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9, 2018, and continuing through on or about May 16, 2019, in the Middle
District of Florida and elsewhere, the defendants,

and
aiding and abetting each other, did knowingly obstruct, delay, and affect, and
attempt to obstruct, delay, and affect, in any way and degree, commerce and
the movement of articles and commodities in commerce by extortion, as such
terms are defined in 18 U.S.C. § 1951, that is, the defendants, acting in concert
with one another, obtained property not due defendants, from Client B with
Client B's consent, under color of official right and through fear of economic
harm.
In violation of 18 U.S.C. §§ 1951(a) and 2.
COUNTFOUR
(Failure to File Form 8300)
A. Introduction
1. Paragraphs I through 6 of Count One of this Indictment are
realleged as if fully set forth herein.
B. Charge
2. On or about August 23, 2018, in the Middle District of Florida,
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defendant,
MARION l\IlCHAEL O'STEEN,
who was engaged in a trade and business, that is M. Michael O'Steen, P.A.,
and who in the course of such trade and business, received more than $10,000
in currency in one transaction, did willfully fail to file a report, to wit: Form
8300, with the Financial Crimes Enforcement Network, within fifteen days after
the currency is received, as prescribed by the applicable regulations under 31
U.S.C. § 5331(b).
All in violation of 31 U.S.C. §§ 5331 and 5322, and 31 C.F.R.
§ 1010.330(a).
COUNT FIVE
( Conspiracy to Commit Federal Program Bribery)
A. Introduction

0~
1. Paragraphs 1 through 6 of Count One'this Indictment are realleged
and incorporated as if fully set forth herein.
2. Ernest Maloney Page, IV, ("Page") was a criminal defense
attorney until or about March 31, 2019, practicing law in the Middle District of
Florida, and elsewhere, and a licensed member of The Florida Bar.
3. "Client D" was a resident of the Middle District of Florida who

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managed a family-owned tractor dealership in the Middle District of Florida.
Client D retained Page to represent him after Client D was arrested on two
separate occasions and charged by the State Attorney's Office for Driving Under
the Influence ("DUI") in Madison County, Florida.
B. The Conspiracy
4. Beginning in or around July 2017, and continuing through on or
about March 12, 2020, in the Middle District of Florida, and elsewhere,
defendant,
JEFFREY ALAN SIEGMEISTER,
did knowingly and willfully combine, conspire, confederate, and agree with
Page and others, both known and unknown to the Grand Jury, to commit
certain offenses against the United States, that is bribery concerning programs
receiving federal funds, in violation of 18 U.S.C. § 666(a)(l)(B).
C. Manner and Means
5. The manner and means by which the conspirators sought to
accomplish the purpose of the conspiracy included, among other things:
a. It was a part of the conspiracy that SIEGMEISTER would
and did use his position as the State Attorney to solicit, accept, and agree to
accept bribes in return for the favorable disposition of criminal cases.
b. It was further part of the conspiracy that SIEGMEISTER
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and Page would and did discuss and agree that Page would provide and promise
to provide a bribe from Client D in exchange for SIEGMEISTER reducing or
dismissing the charges brought by the State Attorney's Office against Client D.
c. It was a further part of the conspiracy that Page would and
did relay messages from SIEGMEISTER to Client D for the purpose of
facilitating a bribe to SIEGMEISTER in exchange for favorable dispositions of
Client D's cases.
d. It was further part of the conspiracy that Client D would
and did provide and promise to provide a bribe to SIEGMEISTER, in exchange
for disposition of the charges brought by the State Attorney's Office against
ClientD.
e. It was a further part of the conspiracy that the conspirators
would and did perform acts and make statements to hide and conceal, and cause
to be hidden and concealed, the object of the conspiracy and the acts committed
in furtherance thereof.
D. Overt Acts
6. In furtherance of the conspiracy and to effect the objects thereof,
the conspirators committed and caused to be committed, within the Middle
District of Florida and elsewhere, the following overt acts, among others:
a. In or around July 2017, Page told SIEGMEISTER to visit
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Client D at Client D's family's tractor dealership because SIEGMEISTER
wanted a new tractor.
b. In or around September 2017, SIEGMEISTER sent his wife
to Client D's tractor dealership to obtain an estimate for the purchase of a tractor
and accessories.
c. In or around September 2017, SIEGMEISTER told Page
that SIEGMEISTER would reduce one of Client D's pending DUI cases in
exchange for a bribe in the form of a $10,000 discount on the purchase of a
tractor and accessories, and SIEGMEISTER would reduce both of Client D's
pending DUI cases in exchange for a bribe in the form of a $20,000 discount on
the purchase of a tractor and accessories.
d. In or around September 2017, Page relayed to Client D
SIEGMEISTER's offer to receive a bribe from Client D.
e. In or around September 2017, Client D agreed to pay
SIEGMEISTER a bribe in exchange for reducing both of his criminal DUI cases
pending before the State Attorney's Office, specifically to provide
SIEGMEISTER with a $20,000 discount on a tractor and tractor accessories.
f. In or around September 2017, Page told SIEGMEISTER
that Client D had agreed to pay SIEGMEISTER a bribe in the form of a $20,000
discount on a tractor and accessories in exchange for reducing both of Client
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D's pending DUI charges.
g. On or about September 20, 2017, SIEGMEISTER's wife
purchased a tractor and accessories from Client D, the price of which was
discounted by approximately $20,000.
h. On or about September 28, 2017, SIEGMEISTER, Client
D, and Page signed an Offer of Plea, which provided that Client D would plead
no contest to the charges of reckless driving with alcohol and refusal to submit
to blood alcohol test in exchange for both DUI charges being dismissed by the
State Attorney's Office.
1. On or about September 28, 2017, SIEGMEISTER agreed
in the Offer of Plea that Client D receive a sentence of 12 months' supervised
probation with no incarceration.
COUNT SIX
(Federal Program Bnl>ery)
A. Introduction
1. Paragraphs 1 through 3 of Count Five of this Indictment are
realleged and incorporated as if fully set.forth herein.
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B. Charge
2. From in or around July 2017, and continuing through on or about
September 28, 2017, in the Middle District of Florida, and elsewhere,
defendant,
did knowingly, willfully, and corruptly solicit and demand for his own benefit,
and accept and agree to accept something of value, that is, an approximately
$20,000 discount on a tractor from Client D, from someone other than the State
Attorney's Office for the Third Judicial Circuit of Florida, intending to be
influenced and rewarded in connection with a business, transaction, and series
of transactions of the State Attorney's Office for the Third Judicial Circuit of
Florida, involving something worth $5,000 or more, that is the criminal matter
of Client D, and during each of the one-year periods of July I, 2016, through
June 30, 2017, and July 1, 2017, through June 30, 2018, the State Attorney's
Office for the Third Judicial Circuit of Florida received in excess of $10,000
under Federal programs involving a grant, contract, subsidy, loan, guarantee,
insurance, and other form of Federal assistance.
In violation of 18 U.S.C. §§ 666(a)(l)(B) and 2.
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COUNTS SEVEN THROUGH NINE

(Wire Fraud)
A. Introduction
1. Paragraph I of Count One of this Indictment is realleged and
reincorporated as if fully set forth herein.
2. L.T. was an elderly man with physical and mental deficiencies
who resided in Columbia County, Florida, for whom SIEGMEISTER was
appointed as legal guardian by the Circuit Court of the Third Judicial Circuit,
in and for Columbia County, Florida.
B. The Scheme and Artifice
3. From an unknown date, but at least from in or about January
2010, continuing through and including in or around April 2016, in the Middle
District of Florida, and elsewhere, the defendant,
did knowingly and intentionally devise and intend to devise a scheme and
artifice to defraud, and for obtaining money and property by means of
materially false and fraudulent pretenses, representations, and promises.
C. Manner and Means of the Scheme
4. The manner and means by which the defendant and others carried
out the scheme and artifice included, among other things:

21
a. It was part of the scheme and artifice that SIEGMEISTER
would and did petition the Circuit Court of the Third Judicial Circuit, in and
for Columbia County, Florida, to become the guardian for L.T., who was then
80 years of age, on which petition SIEGMEISTER noted that L.T. owned
10,248 shares of Coca-Cola Common Stock, with a value of$664,751.93.
b. It was further part of the scheme and artifice that
SIEGMEISTER would and did petition the court for expenses associated with
the preparation of a will for L. T.
c. It was further part of the scheme and artifice that
SIEGMEISTER would and did cause to be drafted a Last Will and Testament
for L.T. that:
1. named SIEGMEISTER's relative as the sole
beneficiary ofL.T.'s assets; and
11. designated SIEGMEISTER as the Personal
Representative of the L.T. Estate.
d. It was further part of the scheme and artifice that, while still
serving as the court-appointed voluntary guardian for L.T., SIEGMEISTER
would and did convert and caused to be converted L. T. 's assets into cash, which
was deposited to accounts under SIEGMEISTER's control, utilizing interstate
wire transmissions.
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e. It was further part of the scheme and artifice that after
converting L.T.'s assets to cash and depositing the cash to accounts under
SIEGMEISTER's control, SIEGMEISTER would and did purchase assets for
himself, utilizing interstate wire transmissions.
f. It was further part of the scheme and artifice that
SIEGMEISTER would and did file a Final Accounting of Guardian Property
with the Probate Division of the Circuit Court for Columbia County, Florida,
which contained materially false and fraudulent expense information for the
L.T. Guardianship.
g. It was further part of the scheme and artifice that
SIEGMEISTER filed or caused to be filed, a Petition for Administration with
the Probate Division of the Circuit Court of the Third Judicial Circuit, in and
for Columbia County, Florida, which contained materially false and fraudulent
asset and expenditure information for the L.T. Estate.
h. It was further part of the scheme and artifice that
SIEGMEISTER's misrepresentations concealed the diversion of L.T.'s assets,
allowing the Probate Division of the Circuit Court for Columbia County,
Florida, to Order L.T.'s Last Will and Testament to Probate and appointing
SIEGMEISTER as Personal Representative, and as such SIEGMEISTER
would continue to divert the assets ofL.T.'s Estate to himself and to his relative
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without detection.
1. It was further part of the scheme and artifice that, while
serving as the Personal Representative of the L.T. Estate, SIEGMEISTER
diverted assets from the L.T. Estate to accounts controlled by SIEGMEISTER
and his relative, utilizing interstate wire transmissions.
J. It was further part of the scheme and artifice that
SIEGMEISTER would not and did not report to the Probate Division of the
Circuit Court for Columbia County, Florida that he and his relative were
receiving significant financial benefits from L. T. and his Estate despite the
conflict of interest and violations of Florida State statutes concerning
Guardianships.
k. It was further part of the scheme and artifice that
SIEGMEISTER would not and did not report and cause the reporting of the
funds he diverted to himself from L.T. and the L.T. Estate as income on his
federal income tax returns in tax years 2015 and 2016.
D. Interstate Wire Transmissions
5. On or about the date listed below in each count, in the Middle
District of Florida, and elsewhere, the defendant,
for the purpose of executing the aforementioned scheme and artifice, knowingly
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and intentionally transmitted and caused to be transmitted by means of wire
communication interstate commerce, the writings, signs, and signals associated
with funding the below-listed checks:
COUNT ONOR TRANSACTION PAYOR DEPOSIT

ABOUT ACCOUNT ACCOUNT
SEVEN February Deposit of Check Bank of First Federal

25,2016 No. 122937, in America Bank account
the amount of account ending ending in 4706,
$313,816.52, in 7385, held by held by The
payable to Computershare, Siegmeister Law
"Jeffrey A Inc. for the Firm PA (Trust
Siegmeister Per benefit of The Account IOTA)
Rep Est L.W.T." Coca-Cola
from Company
Computershare,
Inc. account held
for the benefit of
The Coca-Cola
Company
EIGHT March Deposit of Check First Federal Columbia Bank
7,2016 No. 1219, in the Bank account account ending
amount of ending in 4706, 8160, held by
$264,500, payable held by The Jeffrey A
to "N.A.B. or Siegmeister Siegmeister and
Jeffrey A. Law Firm PA J.L.S.
Siegmeister" from (Trust Account
The Siegmeister IOTA)
Law Firm PA
IOTA Trust
Account
25
NINE March Deposit of Check Harris Central, First Federal

24,2016 No. 6585699, in N.A. account Bank account
the amount of ending in 5361, ending 4706 held
$11,634.47, held by by The
payable to Computershare, Siegmeister Law
"Jeffrey A. Inc. for the Firm PA (Trust
Siegmeister Per benefit of The Account IOTA)
Rep Est L.W.T." Coca-Cola
from Company
Computershare,
Inc. account held
for the benefit of
The Coca-Cola
Company
COUNTTEN
(Filing False Tax Return)
A. Introduction
1. Paragraphs 1 through 5 of Counts Seven through Nine of this
Indictment are realleged as if fully set forth herein.
B. Charge
2. On or about April 17, 2016, in the Middle District of Florida, and
elsewhere, the defendant,
did willfully make and subscribe, and cause to be made and subscribed, a 2015
U.S. Individual Income Tax Return, IRS Form 1040, which was verified by a
26
written declaration that it was made under penalties of perjury, and which he
did not believe to be true and correct as to every material matter, that the return
was filed with the Internal Revenue Service, and reported his total income on
Line 22 of Form 1040 as $150,313, whereas, as he then and there well knew and
believed his total income was greater than reported.
In violation of 26 U.S.C. § 7206(1).
COUNT ELEVEN
A. Introduction
1. Paragraphs 1 through 5 of Counts Seven through Nine of this
Indictment are realleged as if fully set forth herein.
B. Charge
2. On or about April 16, 2017, in the Middle District of Florida, and
did not believe to be true and correct as to every material matter, that the return
was filed with the Internal Revenue Service, and reported his total income on
27
Line 22 of Form 1040 as ($150,128), whereas, as he then and there well knew
and believed his total income was greater than reported.
COUNT TWELVE
A. Introduction
1. Paragraphs 1 through 3 of Count Five of this Indictment are
realleged as if fully set forth herein.
B. Charge
2. On or about March 13, 2018, in the Middle District of Florida, and
did not believe to be true and correct as to every material matter, in that the
return was filed with the Internal Revenue Service, and reported his total
income on Line 22 of Form 1040 as $24,146, whereas, as he then and there well
knew and believed his total income was greater than reported.
28
FORFEITURE
1. The allegations contained in Counts One through Three and
Counts Five through Nine, are incorporated by reference for the purpose of
alleging forfeiture, pursuant to provisions of 18 U.S.C. § 981(a)(l)(C) and 28
U.S.C. § 2461(c).
2. Upon conviction of a conspiracy of the violation of 18 U.S.C.
§ 1952, in violation of 18 U.S.C. § 371, charged in Count One, and/or upon
conviction of a conspiracy of, or a violation of, 18 U.S.C. § 1951, charged in
Counts Two and Three, the defendants, JEFFREY ALAN SIEGMEISTER and
MARION MICHAEL O'STEEN, shall forfeit to the United States of America,
pursuant to 18 U.S.C. § 981(a)(l)(C), and 28 U.S.C. § 2461(c), any property, real
or personal, which constitutes or is derived from proceeds traceable to the
violation.
3. Upon conviction of a conspiracy of the violation of 18 U.S.C.
§ 666(a)(l)(B), in violation of 18 U.S.C. § 371, charged in Count Five, and/or
up conviction of a violation of 18 U.S.C. § 666(a)(l)(B), charged in Count Six,
the defendant, JEFFREY ALAN SIEGMEISTER, shall forfeit to the United
States, pursuant to 18 U.S.C. § 981(a)(l)(C) and 28 U.S.C. § 2461(c), any
property, real or personal, which constitutes or is derived from proceeds
traceable to the offense.
29
4. Upon conviction of a violation of 18 U.S.C. § 1343, charged in
Counts Seven through Nine, the defendant, JEFFREY ALAN
SIEGMEISTER, shall forfeit to the United States of America, pursuant to 18
U.S.C. § 981(a)(l)(C) and 28 U.S.C. § 2461(c), any property, real or personal,
which constitutes or is derived from proceeds traceable to the violation.
5. The property to be forfeited includes, but is not limited to, the
following:
a. an order of forfeiture in the amount of at least $60,000.00

which represents the amount of proceeds the defendants,
JEFFREY ALAN SIEGMEISTER and MARION
MICHAEL OSTEEN, obtained as a result of the offenses
charged in Counts One through Three;
b. an order of forfeiture in the amount of at least $27,000.00

which represents the amount of proceeds the defendant,
JEFFREY ALAN SIEGMEISTER, obtained as a result of
the offenses charged in Counts Five and Six;
c. an order of forfeiture in the amount of$640,995.71, which

represents the amount of proceeds the defendant,
JEFFREY ALAN SIEGMEISTER, obtained as a result of
the offenses charged in Counts Seven through Nine;
d. 7,372 shares of The Coca-Cola Company common stock

held by Computershare Shareholder Services, Inc.,
account Number C0006753353, held in the names of
Nancy A. Bowen & William G Bowen Joint Tenants; and
e. Real property, including all improvements thereon and

appurtenances thereto, located at 2637 145th Road, Live
Oak, Suwannee County, FL 32060, more particularly
described as:
30
a) The N½ ofNE¼ of SE¼ of Section 18, Township I

South, Range 13 East, Suwannee County, Florida;
and
b) The SW¼ of NE¼ and the North 330 feet of the

NW¼ of SE¼ of Section 18, Township I South,
Range 13 East, Suwannee County, Florida.
Parcel Identification Number: 0467500-3000.
6. If any of the property described above, as a result of any act or
omission of the defendants:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third
person;
c. has been placed beyond the jurisdiction of the Court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be
subdivided without difficulty;
31
Case 3:21-cr-00016-MMH-JBT Document 1 Filed 02/24/21 Page 32 of 33 PagelD 32
the United States shall be entitled to forfeiture of substitute property under the
provisions of21 U.S.C. § 853(p), as incorporated by 28 U.S.C. § 2461(c).
MARIA CHAPA LOPEZ

United States Attorney
By: ~ie~
Assistant United States Attorney
By:
David Mesrobian
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By: ~ ~ - --
_.......Frank Talbot
Chief, Jacksonville Division
32
FORMOBD-34
2/23/21 Revised No.
UNITED STATES DISTRICT COURT ()

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Jeffrey Siegmeister Indictment

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Jeffrey Siegmeister Indictment

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What charges were brought against Jeffrey Siegmeister and Marion O'Steen?

What charges were brought against Jeffrey Siegmeister and Marion O'Steen?

What criminal cases did Marion O'Steen represent clients for?

What criminal cases did Marion O'Steen represent clients for?

Case 3:21-cr-00016-MMH-JBT Document 1 Filed 02/24/21 Page 1 of 33 PageID 1

FILED IN OPEN COURT

UNITED STATES OF AMERICA

V. CASE NO. 3:21-cr- I (p-1'\M ~ - "YJ3T

The Grand Jury charges:

At all times material to this Indictment:

1. JEFFREY ALAN SIEGMEISTER ("SIEGMEISTER") was a

Third Judicial Circuit of Florida ("the State Attorney's Office"). Prior to

becoming the State Attorney, SIEGMEISTER was a private attorney in private

practice in Lake City, Florida.

2. MARION MICHAEL O'STEEN ("O'STEEN") practiced law in

Florida Bar. O'STEEN maintained a law office in Dixie County, Florida.

3. The State Attorney's Office was an agency of the State of Florida,

covering counties in the Middle District of Florida, and elsewhere, including

Columbia, Dixie, Hamilton, Lafayette, Madison, Suwannee, and Taylor

Counties. The State Attorney's Office received annual benefits in excess of

other form of Federal assistance.

4. From at least as early as on or about June 12, 2017, and continuing

through at least on or about April 16, 2018, O'STEEN represented an

charged with attempted first degree murder, arson, possession of a firebomb,

5. From at least as early as on or about February 26, 2018, and

continuing through at least on or about September 12, 2018, O'STEEN

represented an individual, "Client B," with respect to a criminal case in which

6. From at least as early as on or about January 23, 2019, and

continuing through at least on or about July 15, 2019, O'STEEN represented

Third Judicial Circuit, in and for Dixie County, Florida.

7. From an unknown date but at least in or around November 2017,

Florida and elsewhere, the defendants,

JEFFREY ALAN SIEGMEISTER

facility in interstate and foreign commerce, namely a telephone and wire, to

promote, manage, establish, carry on, and facilitate the promotion,

management, establishment, and carrying on of an unlawful activity, that is,

bribery, in violation of Florida Statute§ 838.015; and extortion, in violation of

Florida Statute § 836.05, and to perform and attempt to perform an act to

management, establishment and carrying on of the above unlawful activity, in

violation of 18 U.S.C. § 1952(a)(3).

C. Manner and Means of the Conspiracy

conspiracy included, among other things:

a. It was part of the conspiracy that O'STEEN would and did

Attorney, to include favorable disposition of charges filed against criminal

defendants O'STEEN represented.

b. It was further part of the conspiracy that SIEGMEISTER

to accept, bribes in return for the favorable disposition of criminal cases

c. It was further part of the conspiracy that SIEGMEISTER

SIEGMEISTER's herd of Florida Braford bulls m exchange for

SIEGMEISTER's favorable disposition of criminal charges against O'STEEN's

clients upon O'STEEN's request.

d. It was further part of the conspiracy that SIEGMEISTER

against O'STEEN's clients.

e. It was further part of the conspiracy that SIEGMEISTER

O'STEEN to obtain additional "fees" from at least one of O'STEEN's clients.

f. It was a further part of the conspiracy that the conspirators

committed in furtherance thereof.

9. In furtherance of the conspiracy, the defendants committed the

following overt acts in the Middle District of Florida and elsewhere: