SEALED

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA

Criminal No lAcr
Violations:
V.

Count One: Conspiracy to Commit Mail

MARK RIDDELL, Fraud and Honest Services Mail Fraud
(18U.S.C. § 1349)
Defendant

Count Two: Conspiracy to Commit

Money Laundering
(18U.S.C. § 1956(h))

Forfeiture Allegation:
(18 U.S.C.§ 981(a)(1)(C) and
28 U.S.C.§ 2461(c))

Money Laundering Forfeiture Allegation:

(18 U.S.C.§ 982(a)(1))
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INFORMATION
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At all times relevant to this Information:

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General Allegations o m
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1. The defendant, MARK RIDDELL, was a resident of Palmetto, Florida.

2. William Rick Singer, was a resident, variously, of Sacramento and Newport Beach,

California. Singer owned the Edge College & Career Network, LLC and served as chief

executive officer of the Key Worldwide Foundation.

3. The Edge College & Career Network, LLC, also known as "The Key," was a for-

profit college counseling and preparation business that Singer founded in or about 2007 and

incorporated in the State of California in or about 2012.