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UNITED STATES DISTRICT COURTDISTRICT OF NEW JERSEY
 UNITED STATES OF AMERICA:
CRIMINAL COMPLAINT
:v.::ANTHONY R. SUAREZ and:VINCENT TABBACHINO:Mag. No. 09-8140 (MCA)I, Robert J. Cooke, being duly sworn, state the following is true and correct to the best of myknowledge and belief.SEE ATTACHMENT AI 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 Bcontinued 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
M
ADELINE
C
OX
A
RLEO
 U
NITED
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TATES
M
AGISTRATE
J
UDGE
Signature of Judicial Officer
 
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ATTACHMENT A
COUNT 1
From in or about May 2009 to in or about July 2009, inBergen County, in the District of New Jersey and elsewhere,defendantsANTHONY R. SUAREZandVINCENT TABBACHINOdid knowingly and willfully conspire to obstruct, delay, andaffect interstate commerce by extortion under color of officialright, by accepting and agreeing to accept corrupt payments thatwere paid and to be paid by another, with that person’s consent,in exchange for defendant ANTHONY R. SUAREZ’s future officialassistance in Ridgefield Government matters.In violation of Title 18, United States Code, Sections1951(a) and 2.
COUNT 2
From on or about February 4, 2009 to in or about June 2009,in Hudson County, in the District of New Jersey and elsewhere,defendantVINCENT TABBACHINOknowingly and willfully conducted and attempted to conduct afinancial transaction involving property represented by a personacting at the direction of federal law enforcement authorities tobe the proceeds of specified unlawful activity, specifically, thetrafficking in counterfeit goods, contrary to Title 18, UnitedStates Code, Section 2320 and Section 2, with the intent toconceal and disguise the nature, location, source, ownership, andcontrol of the property believed to be proceeds of specifiedunlawful activity.In violation of Title 18, United States Code, Section1956(a)(3).
 
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ATTACHMENT BI, 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 AttachmentB 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, defendantAnthony R. Suarez (hereinafter, “defendant Suarez”) served as theMayor of the Borough of Ridgefield, New Jersey. Defendant Suarezwas initially elected to the Ridgefield Borough Council in orabout 1998, was reelected to the Borough Council in or about 2001and first elected as Mayor in or about 2003. Defendant Suarezwas reelected to a four-year term as Mayor in or about 2007.Defendant Suarez also is an attorney at a firm based in Fort Lee,New Jersey.2. At all times relevant to this Complaint, defendantVincent Tabbachino (hereinafter, “defendant Tabbachino”) was theproprietor of a tax preparation business located in Guttenberg,New Jersey.3. There was a cooperating witness (the "CW") who hadbeen charged with bank fraud in a federal criminal complaint inMay 2006. Thereafter, for the purposes of this investigationconducted by the FBI, the CW posed as: (a) a real estatedeveloper interested in development in the greater Hudson/BergenCounty area, to include the Borough of Ridgefield and (b) theowner of a counterfeit handbag business. The CW represented thatthe CW did business in numerous states, including New York andNew Jersey, and that the CW paid for goods and services ininterstate commerce.
COUNT 1
4. On or about May 18, 2009, defendants Suarez andTabbachino met the CW at a restaurant in Fairview, New Jersey.During the meeting, defendant Suarez discussed two properties inRidgefield which he believed might be of interest to the CW, andindicated that another party was potentially interested inpurchasing one of them. Defendant Suarez informed the CW,however, that he believed that this property remained availablefor purchase. Defendant Suarez did inquire “[i]f somethinghappened where you couldn’t–-where something happened with theone property, would you still be willing to grab the other
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