According to the complaint, on approximately June 14, a confidential witness who works in the security department for a multinational corporation in New Orleans notified the FBI that Roussel contacted him and told him that he had a friend in Texas and that Gladius would provide armed guards to the company after a hurricane. It is alleged that Roussel told the witness that if the witness gave Roussel's friend a contract, the officer's friend would "kick back" money to both Roussel and the witness.
The witness subsequently met with Roussel and Branch in New Orleans. During this meeting, they agreed to a rate of $89.50 per hour per guard with an inflated portion of approximately $15 per hour, per guard. The three then agreed to an equal split of the $15 inflated fraudulent charge. On June 22, the three were scheduled to meet at the company's offices in New Orleans to sign a contract that included the inflated prices.
If convicted of the wire fraud, Roussel and Branch face a maximum term of imprisonment of 30 years, a $1 million fine, and a five-year parole.