AO 91 (REV.5/85) Criminal ComplaintAUSAs Margaret J. Schneider (312) 353-1875, Michael T. Donovan (312) 886-2035, Brandon D. Fox (312) 353-5277
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UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOISEASTERN DIVISIONUNITED STATES OF AMERICAv.DEAN NICHOLS,REGGI HOPKINS,ELLIOTT KOZEL,ANTHONY JOHNSON,MARY SMITH,REGINA HOLLIE, andBRYANT JESSUP
CRIMINAL COMPLAINT
CASE NUMBER:
UNDER SEAL
I, the undersigned complainant, being duly sworn on oath, state that the following is true and correct to thebest of my knowledge and belief:
COUNT ONE
From in or about September 2011 to no later than February 2012, at Oak Park and Chicago, in the NorthernDistrict of Illinois, Eastern Division DEAN NICHOLS and REGGI HOPKINS, defendants herein:conspired to commit an offense against the United States, specifically bribery of a public official (18U.S.C. § 201(b)(1)), by agreeing to directly and indirectly, corruptly give, offer and promise a thingof value, namely money, to a purported Health and Human Services (“HHS”) official, with the intentto influence that official’s awarding of HHS grants;in violation of Title 18, United States Code, Section 371.
COUNT TWO
From in or about September 2011 to no later than November 2011, at Oak Park and Chicago, in the NorthernDistrict of Illinois, Eastern Division DEAN NICHOLS and ELLIOTT KOZEL, defendants herein:conspired to commit an offense against the United States, specifically bribery of a public official (18U.S.C. § 201(b)(1)), by agreeing to directly and indirectly, corruptly give, offer and promise a thingof value, namely money, to a purported HHS official, with the intent to influence that official’sawarding of HHS grants;in violation of Title 18, United States Code, Section 371.
COUNT THREE
From in or about January 2012 to no later than February 2012, at Oak Park and Chicago, in the NorthernDistrict of Illinois, Eastern Division DEAN NICHOLS and ANTHONY JOHNSON, defendants herein:conspired to commit an offense against the United States, specifically bribery of a public officialpursuant to 18 U.S.C. § 201(b)(1), by agreeing to directly and indirectly, corruptly give, offer andpromise a thing of value, namely money, to a purported HHS official, with the intent to influencethat official’s awarding of HHS grants;in violation of Title 18, United States Code, Section 371.
COUNT FOUR
From in or about November 2011 to no later than January 2012, at Chicago, in the Northern District of Illinois, Eastern Division, ELLIOTT KOZEL and MARY SMITH, defendants herein:conspired to commit an offense against the United States, specifically bribery of a public officialpursuant to 18 U.S.C. § 201(b)(1), by agreeing to directly and indirectly, corruptly give, offer andpromise a thing of value, namely money, to a purported HHS official, with the intent to influencethat official’s awarding of HHS grants;in violation of Title 18, United States Code, Section 371.
COUNT FIVE
From in or about November 2011 to no later than February 2012, at Chicago, in the Northern District of Illinois, Eastern Division, ELLIOTT KOZEL and REGINA HOLLIE, defendants herein:conspired to commit an offense against the United States, specifically bribery of a public officialpursuant to 18 U.S.C. § 201(b)(1), by agreeing to directly and indirectly, corruptly give, offer andpromise a thing of value, namely money, to a purported HHS official, with the intent to influencethat official’s awarding of HHS grants; in violation of Title 18, United States Code, Section 371.
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COUNT SIX
From in or about February 2012 to no later than March 2012, at Chicago, in the Northern District of Illinois,Eastern Division, ELLIOTT KOZEL and BRYANT JESSUP, defendants herein:conspired to commit an offense against the United States, specifically bribery of a public officialpursuant to 18 U.S.C. § 201(b)(1), by agreeing to directly and indirectly, corruptly give, offer andpromise a thing of value, namely money, to a purported HHS official, with the intent to influencethat official’s awarding of HHS grants;in violation of Title 18, United States Code, Section 371.I further state that I am a Special Agent with the Federal Bureau of Investigation, and that this complaintis based on the facts contained in the Affidavit which is attached hereto and incorporated herein. Signature of ComplainantBRENDAN O’LEARYSpecial Agent, Federal Bureau of InvestigationSworn to before me and subscribed in my presence,July 16, 2012 atDateChicago, IllinoisCity and StateJeffrey Cole, U.S. Magistrate JudgeName & Title of Judicial Officer Signature of Judicial Officer
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