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College Cheating Scandal — Augustin Huneeus, Jr — From Department of Justice Complaint Pages 96-107

Agustin Huneeus Jr.

Conspiracy to commit mail fraud and honest services mail fraud.


Huneeus, of San Francisco, owns Huneeus Vintners, which owns Quintessa and numerous other wine brands.



 Below is a direct, unedited excerpt from pages 97-108 of DoJ Complaint.pdf

Note: In the full document, CW-1, CW-2, and CW-3 are identified by the FBI as Cooperating Witnesses (CW). See footnotes in for more  DoJ Complaint.pdf description on them.



221. Defendant AGUSTIN HUNEEUS, Jr. is a resident of San Fransico, California. HUNEEUS is an owner of vineyards in Napa, California and elsewhere.
222. In or about 2017 and 2018, HUNEEUS participated in both the college entrance exam cheating scheme and the college recruitment scheme for his daughter, including by conspiring to bribe Heinel and Jovan Vavic, the USC water polo coach,18 to facilitate his daughter’s admission to USC as a purported water polo recruit.
223. CW-1 has advised law enforcement agents that, in exchange for HUNEEUS’s purported contribution of $50,000 to KWF, CW-1 arranged for CW-2 to purport to proctor the SAT exam for HUNEEUS’s daughter at the West Hollywood Test Center in or about March 2018. According to CW-1, he explained to HUNEEUS that he “controlled” the test center, and that CW-2 would correct his daughter’s answers after she completed the exam.
224. In an e-mail to HUNEEUS and a psychologist selected by CW-1 on or about May 25, 2017, CW-1 noted that HUNEEUS’s daughter “needs testing for 100 percent time with multiple days” and directed HUNEEUS and the psychologist to “[p]lease connect.”
18 Vavic has been indicted by a federal grand jury in the District of Massachusetts on a charge of racketeering conspiracy, in violation of Title 18, United States Code, Section 1962(d).
225. In or about August 2017, the psychologist provided HUNEEUS’s daughter with documentation recommending that she receive extended time on the SAT. On or about October 7, 2017, the College Board granted HUNEEUS’s daughter extended time to take the exam over successive days.
226. On or about January 22, 2018, HUNEEUS forwarded CW-1 an e-mail he had received from an employee at his daughter’s high school, indicating that she planned to proctor his daughter’s test at the school on March 10th and March 11th. HUNEEUS wrote, “Here is the email.” CW-1 replied, “You can tell her you are going to be out of town and have found a location to provide the test so [your daughter] does not have to miss school. The school is [the West Hollywood Test Center] for your use.”
227. On or about February 16, 2018, an employee at the high school wrote to HUNEEUS that HUNEEUS’s executive assistant “had mentioned trying to arrange for [his daughter] to take the exam in L.A. If that is the case, please make sure the [College] Board knows where to send the exam.” That same day, Dvorskiy e-mailed CW-1 confirmation that the College Board had shipped SAT materials for HUNEEUS’s daughter to the West Hollywood Test Center. CW-1 forwarded the confirmation to HUNEEUS. On or about February 21, 2018, a College Board representative confirmed in an e-mail to HUNEEUS’s daughter and Dvorskiy that “[W]e have received confirmation that [the West Hollywood Test Center] is able to accommodate your testing for the March SAT.”
228. On or about March 9, 2018, CW-2 flew from Tampa to Los Angeles to proctor HUNEEUS’s daughter exam on March 10, 2018. CW-2 has advised investigators that while there he met with HUNEEUS, who brought his daughter to the exam. According to CW-2, he
assisted HUNEEUS’s daughter to answer questions during the exam, and corrected her answers after she had completed it. CW-2 returned to Tampa on or about March 11, 2018.
229. On or about April 3, 2018, HUNEEUS wired $50,000 as a purported charitable contribution to KWF. CW-1, in turn, paid Dvorskiy and CW-2 $10,000 each.
230. HUNEEUS’s daughter received a score of 1380 out of a possible 1600 on the SAT, which was in the 96th percentile nationally. HUNEEUS subsequently complained about the score in a call with CW-1 on or about August 30, 2018. The following are two excerpts from the call, which was intercepted pursuant to a Court-authorized wiretap.
CW-1 The whole world is scamming the system. And I got ’em, ’cause I have a ton of kids who have extended time and they shouldn’t get extended time.
HUNEEUS No, I know you do. I kn– I know your system well. I wha– what my concern is, wha– what I’m trying to understand is that I, it feels like, you know, you, you have a plan for the system, so you know, if you had wanted to, I mean [my daughter’s] score could have been 1550 right?
CW-1 No. ’Cause I would have got investigated for sure based on her grades.
CW-1 Absolutely, th– now we got a bigger problem.
CW-1 Now she’s gonna have to take it at her school in front of everybody.
CW-1 And now when she gets 1100, 1200, now what do we do?
HUNEEUS Oh huh. Um.
HUNEEUS Is Bill McGLASHEN doing any of this shit? Is he just talking a clean game with me and helping his kid or not? ’Cause he makes me feel guilty.
CW-1 Um–
HUNEEUS Or are you just taking care of him in a way that he doesn’t know because you have other interests with him?
CW-1 No, no, let me– not at all. Nothing to do with his– I will say this.
HUNEEUS But he didn’t know– his kid had no idea and he didn’t have any idea that you helped him on the ACT, or the test you took.
CW-1 ’Cause that was what he he asked for.
CW-1 Asked for [his son] not knowing.
CW-1 All right, so he has not been as forthcoming–
HUNEEUS With me?
CW-1 With you, and with his own kid, which is– he wants it that way.
231. In the same call, CW-1 also explained the college recruitment scheme to HUNEEUS. The following are three excerpts from the call.
HUNEEUS I just wanted you to walk me through the whole, kinda, water polo thing again and how it works. You and I did, you know, like the economics, the timing, how all that works. You and I had a brief conversation about it, but I wanted to kinda get it straight, if you don’t mind?
CW-1 Okay, okay. So, I’m putting together, I need to put together [your daughter’s] sports profile. It will be a water polo profile, now.
HUNEEUS Yup, yup.
CW-1 I take her transcript, test scores, and profile to th– to the senior women’s athletic director, who actually is the liaison for all sports at USC, football, everybody has to go through her.
CW-1 And then she, they have meetings every other Thursday, which are called subcommittee meetings, where the dean of admissions, and two admissions off– two admissions staff and she are there, and they go through the athletes for that particular subcommittee meeting. It could be water polo this week, it could be football the next week, it could be basketball. Just depends on where they are in the seasons and what’s going on.
CW-1 So what she does is, she already works on presenting the kids before she gets to the meeting so she knows everything about them, she knows why they want them, she knows where to slot them based on their GPA and test score, and be ready to answer questions if admissions has questions.
CW-1 [Your daughter will] get presented and if they, in the committee if they say okay good, she’s in, then what happens is Donna [Heinel] tells me she’s in, we’re good, and then she gets a letter from admissions, which’ll say in there she’s been admitted, conditionally admitted, she needs to do her NCAA clearing house, she needs to send her transcripts to the NC clearing house, blah, blah, blah, blah, so on, so forth. That letter will come to me and I’ll send that letter to you, and you can hold the letter yourself, she won’t know anything. At that point, you will write a check for $50,000 that will, I’ll give you the address, and exactly who– it will go to Donna Heinel and for senior women’s athletic director. It will be made out to USC Women’s Athletics.
CW-1 Okay? That, that’s essentially just, it goes right in, right to her, she took care of that part, and then when you get your, and then we apply, we send her application. Essentially, you’ve been admitted before she even has applied. Okay?
HUNEEUS Okay, so there’s no chance I give that 50 and then she’s not admitted?
CW-1 You won’t send it until you get the letter.
HUNEEUS Oh, okay. Got it.
CW-1 And then on March 25th, when they send the rest of the letters out, she’ll get her final letter– It’ll be a regular official packet. The normal stuff they normally send out. But you will have already had it in your hands, the same letter in your, so that you know it’s taken care of.
CW-1 At that point, then you will write, we will, my foundation will send you a invoice. You will send a $200,000 check to our foundation, you’ll get your letter, thank you, with your write off, tax ID write off stuff, and then Jovan [Vavic, the water polo coach] will call me and say, “Okay, this is how I want the money split,” and so on and so forth. And that won’t happen until around April 1st.
HUNEEUS Does all of that, do all of those funds go to USC, or do some go to stay in your foundation?
CW-1 No, they go to USC in different ways.
CW-1 So, what Jovan usually does is, I subsidize his staff salaries. . . . I put two of his staff members on my books as contractors. . . . And then I pay them throughout the year . . . . So, this is a way of, all coaches there know that now, so they just call me instead, because they don’t want it to go to the general fund.
CW-1 ’Cause he’s the guy giving up the spot.
232. HUNEEUS acknowledged in the call that his daughter was not qualified to be a USC water polo recruit, and expressed concern about “this thing blow[ing] up in my face.” The following are two additional excerpts from the call.
CW-1 So, in this case it’s gonna be, it, it’s a li– it’s, it’s a little different because Jovan is totally supporting our applications. So, and Jovan–
HUNEEUS And why?
CW-1 Because he owe —
HUNEEUS Because I und–, you understand that [my daughter] is not worthy to be on that team.
CW-1 No, no, he he’s my guy. . . . [A]nd he knows [s]he’s not coming to play, he knows all that.
HUNEEUS And is there any risk that this thing blows up in my face?
CW-1 Hasn’t in 24 years.
CW-1 We’re not doing–
HUNEEUS I know but but the, the, the, the environment. . . . [L]ike some article comes out that the, the–
CW-1 Oh no.
HUNEEUS –polo team is selling seats into the school for 250 grand.
CW-1 Well, no, because she’s a water polo player.
HUNEEUS But she’s not. I mean that’s what I mean–
233. As part of the scheme, CW-1 advised HUNEEUS that Heinel was using a fabricated profile of HUNEEUS’s daughter as a collegiate-level water polo recruit to advance her application within USC. On or about September 18, 2018, shortly before Heinel intended to present HUNEEUS’s daughter to the admissions subcommittee, CW-1 repeated a request that HUNEEUS provide a photograph of his daughter playing water polo. The following is an excerpt from the call, which was intercepted pursuant to the Court-authorized wiretap.
HUNEEUS I’m gonna just call her right now to make sure she has a photo.
CW-1 And if she doesn’t have a photo, what I’m gonna do is, I gotta do something, so I’m–
HUNEEUS No, she’ll have a– [CW-1], she will have a photo.
CW-1 Okay.
HUNEEUS We’ve been talking about this for six fucking months.
CW-1 I totally agree, I totally agree.
234. On or about September 20, 2018, CW-1 sent Heinel an e-mail that included HUNEEUS’s daughter’s high school transcripts, her fraudulent SAT score, and a fabricated athletic profile that falsely identified her as a “3-year Varsity Letter winner” in water polo and “Team MVP 2017,” along with the following photograph, which is of another individual.
235. On or about September 22, 2018, CW-1 advised HUNEEUS that since his daughter had not sent a photograph in time, he had used a photograph of someone else in the profile. The following is an excerpt from the call.
CW-1 I was calling to tell you that we did not make the deadline with her picture. She didn’t send it to me ’till a day later. However I did create the profile with the different picture that, you can’t tell it’s not her, but it’s athletic enough, and put in all the honors and awards to match, and I got it to them on Thursday morning, but they didn’t have a enough time to put her through sub-co so we’ll
probably go in the next couple weeks. But the issue was not getting the picture.
CW-1 So I just wanted you to know kind of what was going on because I told you it would go through Thursday but, and I was texting her all night, all day, and I never got it so the next, ’till a day later.
HUNEEUS: Okay, does that mean her chances change in any way?
CW-1 It means that she didn’t go through sub-co, so– I don’t think it changed as much except for it may she’s gonna go through with a different group of kids, so I don’t know.
236. In a call on or about October 25, 2018, HUNEEUS sought reassurance that his $50,000 payment to Heinel would be returned if his daughter was not admitted to USC. The following is an excerpt from the call, made at the direction of law enforcement, which was consensually recorded.
HUNEEUS And then, if– if for whatever chance she didn’t get in, would– that wouldn’t come back to me, right?
CW-1 Um–
HUNEEUS So I’m taking a bit of a risk there?
CW-1 I– that’s never, ever, ever happened.
CW-1 So I want to say no.
HUNEEUS Okay. Great. So that’s my second question. And then in March we get the real letter.
CW-1 Correct. With everybody else. We get a package that comes from USC. It’s a beautiful thing. The whole thing.
HUNEEUS Okay. And then at that point that’s when my funds go to you, as well?
CW-1 To our foundation, yes.
HUNEEUS To your foundation. Yes. Okay. And the check of that is how much? Remind me again.
CW-1 That’ll be $200,000.
HUNEEUS Okay. And do you need that all in one year?
CW-1 I– I do. I do.
CW-1 And– and we can take it also around June. So you have a little window to play with.
CW-1 And then remember that I have to take that money and pay the folks at USC as they tell me where that money goes.
HUNEEUS No, I un– I understand.
237. In the same call, HUNEEUS also sought reassurance that his daughter would not actually have to join the USC water polo team, despite being admitted as a water polo recruit.
HUNEEUS [CW-1], and then how does this impact– like she– I– I think you’ve said this but I just want to confirm. She actually won’t really be part of the water polo team, right?
CW-1 No, no. She doesn’t have to do anything. She’s just– here’s what’s going to happen. In– in late spring she’s going to get a letter from the– from athletics and adm– and orientation. They’re going to send her a letter saying this is your orientation date. What you’re going to do is not pay attention to it and you’re going to sign up for the first orientation date for regular students and just go to that date and from that point on you’re no longer a part of athletics.
238. Heinel presented HUNEEUS’s daughter to the USC subcommittee for athletic admissions on or about November 2, 2018, using a falsified profile that depicted her as a competitive water polo player.
239. Five days later, on or about November 7, 2018, Heinel e-mailed CW-1 a conditional acceptance letter for HUNEEUS’s daughter stating that she was being admitted to USC because “[y]our records indicate that you have the potential to make a significant contribution to the intercollegiate athletic program.” CW-1 forwarded the letter to HUNEEUS and requested that he “[p]lease send 50K check . . . made payable to USC Women’s Athletic Board . . . to USC Women’s Athletic c/o Donna Heinel.”
240. On or about November 19, 2018, HUNEEUS caused his executive assistant to send a $50,000 check to Heinel by FedEx, payable to “USC Women’s Athletics Board” with the memo line referencing his daughter.
241. On or about November 29, 2018, CW-1 called HUNEEUS from Boston at the direction of law enforcement agents. On the call, CW-1 told HUNEEUS that the IRS was auditing KWF. The following is an excerpt from the call, which was consensually recorded.
CW-1 I just want to give you a heads-up. So I just — they just started an audit on my foundation.
CW-1 So I just want to give you a heads up before McGLASHEN, before anybody, that essentially they’re– they’re going to go– they’ve been asking about both past and present payments. So there’s a payment obviously for 50k in April, for us, taking– for [your daughter] taking the test..
HUNEEUS Yeah, I remember.
CW-1 Okay. So what I want to make sure is that you and I are both on the same page because what I’m going to tell them is that you made a 50k donation to my foundation for underserved kids and not that [CW-2] took the test for [your daughter] or she took the test at [the West Hollywood Test Center].
HUNEEUS Dude, dude, what do you think, I’m a moron?

CW-1 No. It doesn’t– I’m not saying you’re a moron. The point is, is that–.
HUNEEUS I got it, [CW-1]– I got it.
CW-1 Okay.
CW-1 Okay.
HUNEEUS I’m going to say that I’ve been inspired how you’re helping underprivileged kids get into college. Totally got it