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UNITED STATES DISTRICT COURTDISTRICT OF NEW JERSEY
 UNITED STATES OF AMERICA:
CRIMINAL COMPLAINT
:v.::LOUIS MANZO and:RONALD MANZO:Mag. No. 09-8138 (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 January 2009 to in or about April 2009, in Hudson County, in the District of New Jersey and elsewhere, defendantsLOUIS MANZO andRONALD MANZOand 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 LOUIS MANZO’S future official assistance in Jersey CityGovernment 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
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Signature of Judicial Officer
 
ATTACHMENT AI, 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.At all times relevant to this Complaint, defendantLouis Manzo was a candidate for Mayor of Jersey City, New Jersey,which election was held on or about May 12, 2009. He did not winthis election bid. Defendant Louis Manzo previously had servedin the New Jersey General Assembly from 2004 to 2008, where herepresented the 31st legislative district which includes parts ofJersey City. Defendant Louis Manzo also served on the HudsonCounty Board of Chosen Freeholders from in or about 1990 to 1993.2.At all times relevant to this Complaint, defendantRonald Manzo was defendant Louis Manzo’s brother, confidant andpolitical advisor. On or about June 16, 2004, defendant RonaldManzo pleaded guilty in federal district court in the SouthernDistrict of New York to insider trading and committing perjuryduring his testimony before the Securities and ExchangeCommission in connection with his misconduct. At the time,defendant Ronald Manzo was employed as an insurance broker. Onor about June 20, 2007, defendant Ronald Manzo was sentenced to 3years of probation, and was ordered to pay a $250,000 fine.3.At all times relevant to this Complaint:a. There was an individual who served as the VicePresident of the Jersey City Board of Education (until on orabout May 2009), and a commissioner of the Jersey CityHousing Authority (“JC Official 1");.b. There was an individual who represented himself to bethe owner of a consulting firm based in New Jersey (the“Consultant”). The Consultant further represented that theConsultant was an advisor and confidant to defendant LouisManzo, among others.c. There was a cooperating witness (the "CW") who had beencharged with bank fraud in a federal criminal complaint in
 
May 2006. Thereafter, for the purposes of thisinvestigation conducted by the FBI, the CW posed as a realestate developer interested in development in the greaterJersey City area. The CW represented that the CW didbusiness in numerous states, including New York and NewJersey, and that the CW paid for goods and services ininterstate commerce.d.There was an individual who represented himself to bean employee of the Jersey City Department of Health andHuman Services and the Jersey City Zoning Board (“JCOfficial 2"). From in or about March 2008 to in or aboutJuly 2009, JC Official 2 accepted a series of corruptpayments from the CW in exchange for, among other things,assisting the CW with development matters before Jersey CityGovernment and identifying other officials willing to acceptpayments and benefits in exchange for their officialassistance to the CW in local development matters.4.On or about January 7, 2009, JC Official 1 met with theCW at a restaurant in Jersey City. During the conversation,after JC Official 1 and the CW had discussed JC Official 1exerting official influence to assist the CW, JC Official 1explained to the CW that he would seek to introduce the CW toother government officials or politicians who could assist the CWwith the CW’s business interests. In this regard, JC Official 1explained to the CW that he would introduce the CW to “the rightpeople” and agreed with the CW that such people had to be peoplethat JC Official 1 and the CW could trust. JC Official 1 furtherexplained, in substance, that depending on the outcome of themayoral election, either the incumbent Jersey City Mayor ordefendant Louis Manzo would be important for the CW to work within Jersey City. In addition, JC Official 1 explained that JCOfficial 1 also would introduce the CW to the Consultant.5. On or about January 26, 2009, JC Official 1, JC Official2, the CW and others met at a restaurant in Weehawken, NewJersey. The CW was advised by JC Official 2 at the meeting thatthe CW should meet with defendant Louis Manzo in connection withapprovals for the CW’s purported real estate developments inJersey City. JC Official 1 indicated that such meeting had tooccur outside of Jersey City, since JC Official 1, among others,could not openly support defendant Louis Manzo. JC Official 1advised that by meeting with defendant Louis Manzo, they could“cover” both sides of the upcoming mayoral election “just incase,” meaning should defendant Louis Manzo be elected JerseyCity Mayor.6.On or about February 16, 2009, JC Official 1 and the CWmet at a restaurant in Jersey City. During the meeting, among
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