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UNITED STATES DISTRICT COURTDISTRICT OF NEW JERSEY
 UNITED STATES OF AMERICA:
CRIMINAL COMPLAINT
:v.::PETER CAMMARANO III and:MICHAEL SCHAFFER:Mag. No. 09-8128 (MCA)I, Robert J. Cooke, being duly sworn, state the following is true and correct to the best of myknowledge and belief.From in or about April 2009 to in or about July 2009, in Hudson County, in the District of NewJersey and elsewhere, defendantsPETER CAMMARANO IIIandMICHAEL SCHAFFERand others, to include JC Official 1 and the Consultant, did knowingly and willfully conspire to obstruct,delay, and affect interstate commerce by extortion under color of official right, by accepting andagreeing to accept corrupt payments that were paid and to be paid by another, with that person’sconsent, in exchange for defendant PETER CAMMARANO III’s future official assistance in HobokenGovernment matters.In violation of Title 18, United States Code, Sections 1951(a) and 2.I further state that I am a Special Agent with the Federal Bureau of Investigation, and that thiscomplaint is based on the following facts:SEE ATTACHMENT Acontinued on the attached page and made a part hereof. Robert J. Cooke, Special AgentFederal Bureau of InvestigationSworn to before me and subscribed in my presence,July ___, 2009, at Newark, New JerseyH
ONORABLE
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ADELINE
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OX
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RLEO
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NITED
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TATES
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AGISTRATE
J
UDGE
Signature of Judicial Officer
ATTACHMENT A
 
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I, Robert J. Cooke, am a Special Agent with the FederalBureau of Investigation (“FBI”). I have personally participatedin this investigation and am aware of the facts contained herein,based upon my own investigation, as well as information providedto me by other law enforcement officers. Because this AttachmentA is submitted for the limited purpose of establishing probablecause, I have not included herein the details of every aspect ofthe investigation. Statements attributable to individualscontained in this Attachment are related in substance and inpart, except where otherwise indicated. All contacts discussedherein were recorded, except where otherwise indicated.1. Defendant Peter Cammarano III (hereinafter “defendantCammarano”) was an at-large Hoboken Councilman and candidateseeking the position of Mayor of the City of Hoboken. On orabout May 12, 2009, as one of the two top vote getters, defendantCammarano qualified for a run-off election for the mayoralposition. On or about June 9, 2009, Cammarano was elected mayor,and was sworn in on or about July 1, 2009. Defendant Cammaranowas elected to the Hoboken City Council in 2005 and was anattorney specializing in election law until shortly before he waselected mayor.2. Defendant Michael Schaffer (hereinafter “defendantSchaffer”) is a Commissioner on the North Hudson UtilitiesAuthority (“NHUA”) and close associate of Cammarano. Schaffer,who resides in Hoboken, serves as the NHUA’s assistant secretaryand is a member of its Education and Litigation Committees.3.At all times relevant to this Complaint:a. There was an individual (hereinafter, “JC Official1") who represented himself to be in high-levelpositions at the Jersey City Housing Authority (the“JCHA”). In addition, until in or about May, 2009, JCOfficial 1 also served as the Vice President of theJersey City Board of Education ("BOE").b. There was an individual who represented himself tobe the owner of a consulting firm based in New Jersey(the “Consultant”).c. There was a cooperating witness (the "CW") who hadbeen charged with bank fraud in a federal criminalcomplaint in May 2006. Thereafter, for the purposes ofthis investigation conducted by the FBI, the CW posedas a real estate developer interested in development inthe greater Hoboken area. The CW represented that theCW did business in numerous states, including New Yorkand New Jersey, and that the CW paid for goods andservices in interstate commerce.
 
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4. On or about April 11, 2009, at approximately 7:42 p.m.,FBI agents intercepted an incoming call to the Consultant’s homephone
 
from defendant Schaffer, a close associate of theConsultant. During the ensuing conversation, defendant Schafferand the Consultant discussed the upcoming mayoral elections inJersey City and Hoboken. At one point during the conversation,the Consultant referred to the CW as “my guy” and then referredto the CW as “the guy you’re gonna meet,” thus indicating theConsultant’s intention to arrange a meeting between the CW anddefendant Schaffer. The Consultant described the CW as havinggiven another Hudson County public official “20,000 [meaning$20,000]" and indicated that the CW would be providing anadditional $10,000 to this public official before an upcomingelection. The Consultant also told defendant Schaffer that “Iknow [the CW will] give Cammarano 5,000.” The Consultant thenindicated in reference to this payment that “we’ll probably haveto run [the $5,000] through you,” thus indicating that defendantSchaffer was to serve as a middleman for the payment. TheConsultant then detailed the $5,000 and $10,000 payments that theCW already had made or that were scheduled to be made to otherlocal Hudson County government officials and candidates runningfor election. The Consultant remarked that “[JC Official 1]finally found a guy with some money,” and noted that the CW“likes spending money.”5. On or about April 14, 2009, at approximately 3:50 p.m.,FBI agents intercepted an incoming call to the Consultant’s cellphone from JC Official 1. The Consultant stated “a couple ofother things, uh, [Hoboken Councilman Peter] Cammarano would liketo meet on the 27
th
at 2 o’clock at the Malibu Diner. Themeeting to consist of [the CW], you and me, Mike Schaffer andhim. . . ‘cause Mike is gonna deal with, uh, the conversionprocess.”6. On or about April 26, 2009, at approximately 6:44 p.m.,FBI agents intercepted an incoming call to the Consultant’s homephone from defendant Schaffer. During the conversation, theConsultant reminded defendant Schaffer that “we’re seeing eachother at 2 o’clock tomorrow,” prompting defendant Schaffer toreply, “Yup.” The Consultant then confirmed that the meetingwould involve “[j]ust you and Cammarano,” and defendant Schafferreplied, “That’s it. That’s it.” Subsequently, after adiscussion of the Hoboken mayoral campaign, the Consultantexplained “[t]hat’s why we’re gonna try to get this kid[Cammarano] some money tomorrow.” The Consultant opined that “tobe truthful between you and me, there ain’t nothin’ we can do for[the CW] in Hoboken. He builds high rises.” Defendant Schafferdisagreed, noting that “I think you should be able to go high onObserver Highway,” and added that “I think Peter [Cammarano]supports that, too.”7. On or about April 27, 2009, JC Official 1 and the
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