UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOISWESTERN DIVISIONUNITED STATES OF AMERICA))No. 12 CR 50027vs. ) Judge Philip G. Reinhard)RITA A. CRUNDWELL)
PLEA AGREEMENT
1.This Plea Agreement between the Acting United States Attorney for theNorthern District of Illinois, GARY S. SHAPIRO, and defendant RITA A. CRUNDWELL,and her attorneys, PAUL E. GAZIANO and KRISTIN CARPENTER, is made pursuant toRule 11 of the Federal Rules of Criminal Procedure. The parties to this Agreement haveagreed upon the following:
Charge in This Case
2.The indictment in this case charges defendant with wire fraud, in violation of Title 18, United States Code, Section 1343.3.Defendant has read the charge against her contained in the indictment, and thatcharge has been fully explained to her by her attorneys.4.Defendant fully understands the nature and elements of the crime with whichshe has been charged.
Charge to Which Defendant Is Pleading Guilty
5.By this Plea Agreement, defendant agrees to enter a voluntary plea of guiltyto the indictment, which charges defendant with wire fraud, in violation of Title 18, United
States Code, Section 1343. In addition, as further provided below, defendant agrees to theentry of a forfeiture judgment.
Factual Basis
6.Defendant will plead guilty because she is in fact guilty of the charge containedin the indictment. In pleading guilty, defendant admits the following facts and that those factsestablish her guilt beyond a reasonable doubt and establish a basis for forfeiture of theproperty described elsewhere in this Plea Agreement:a.From at least as early as December 18, 1990, and continuing to April17, 2012, defendant knowingly devised and intended to devise a scheme to defraud andobtain more than $53,000,000 from the City of Dixon, Illinois, by means of materially falseand fraudulent pretenses, representations, and promises, and on November 2, 2011, for thepurpose of executing the scheme, knowingly caused to be transmitted by means of wirecommunication in interstate commerce certain signs and signals, namely, a funds transfer inthe amount of $175,000 from the Federal Reserve Bank in Saint Paul, Minnesota, to theFederal Reserve Bank in Cincinnati, Ohio, for credit to City of Dixon’s Capital DevelopmentFund account at Fifth Third Bank in Dixon, Illinois; in violation of 18 U.S.C. § 1343.b.Specifically, defendant admits the following with respect to the schemeto defraud charged in the indictment:i.Between December 18, 1990, and continuing to April 17, 2012,defendant was employed as the comptroller for the City of Dixon, Illinois. As comptroller,defendant supervised the finances for the City of Dixon.
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ii.The City of Dixon, Illinois, maintained a money market accountat US Bank (“Money Market account”) into which were deposited funds representing theCity of Dixon’s share of various tax distributions made by the State of Illinois including themunicipal 1% share of sales tax, local share of income tax, non-home rule sales tax, personalproperty replacement tax, motor fuel tax, local share of state use tax, and simplifiedmunicipal telecommunications tax. The City of Dixon also maintained an account namedthe “Capital Development Fund” at Fifth Third Bank (“Capital Development Fund account”).iii.On December 18, 1990, defendant opened a bank account in thename of the City of Dixon, P.O. Box 386, RSCDA, Dixon, Illinois 61021-0386 at First Bank South (“RSCDA account”), and maintained the RSCDA account at First Bank South and itssuccessor banks, Grand National Bank, Old Kent Bank and Fifth Third Bank. However,defendant did not disclose the existence of this account to the City of Dixon and exercisedtotal control over this account.iv.Defendant used her position as comptroller at the City of Dixonto cause funds to be wired from the City of Dixon’s Money Market account to the City of Dixon’s Capital Development Fund account, as well as to various other City of Dixonaccounts at Fifth Third Bank.v.Defendant wrote and signed checks on various other City of Dixon accounts and deposited those checks into the Capital Development Fund account.vi.After transferring funds from the Money Market account andvarious other City of Dixon accounts into the Capital Development Fund account, defendant
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