court sent 36 checks of $9,000 each to Hills, with written instructions to pay fees owed by the court to the firm. Hills, trusting the intentions of court official Sanchez, facilitated what he thought was a transitional contract for legitimate services between the court and Grennberg Traurig. If done to avoid the federal reporting requirements for payment transfers, this would constitute illegal 'structuring' under 31 USC 5324(a). The form of payment might also be illegal if it was used to evade federal contracting rules requiring an open tender for contracts over $10,000. However, in 2006 the Inspector General of the U.S. Department of Justice issued a report documenting the finding by FBI investigators that no federal funds were involved and no structuring had been carried out. See, pp. 27–31, (If not available go to usdoj.gov, select OIG reports, search for Guam U.S. Attorney, 2006). Allegations of improper influence in the reassignment of Black and appointment of Rapadas also were addressed in the 2006 report of the U.S. Department of Justice, Office of Inspector General, which concluded Black’s allegations of abuse were unfounded, and that Black had used his position to undermine Guam native candidates to replace him. (See: (If not available go to usdoj.gov, select OIG reports, search for Guam U.S. Attorney, 2006).) In 2005, Public Auditor Doris Flores Brooks initiated an investigation of the Abramoff contract and issued a report finding that both the Guam Superior Court and the Guam Supreme Court hired lobbyists in violation of Guam procurement rules, but that the rules did not apply to the courts' lobbying contracts. (See: p. 27, www.guamopa.com, Audit Report 05-08, December 2005.) However, based on the audit report finding that Superior Court payments to Abramoff’s law firm through Hills was intended to circumvent the procurement rules, court administrator Tony Sanchez and Hills were indicted in 2006. Charges against Hills were dismissed after investigations made evident his ethical and non-criminal intentions. Abramoff and the Grennberg Traurig law firm were also indicted in 2006 by the Guam Attorney General Office, and after the law firm paid back the $324,000 which it had received from the court, the entire case was dismissed on February 9, 2009. References History of Guam