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UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOISEASTERN DIVISIONUNITED STATES OF AMERICA))No. 08 CR 888-5vs. ) Judge James B. Zagel)JOHN HARRIS) 
PLEA AGREEMENT
1.This Plea Agreement between the United States Attorney for the NorthernDistrict of Illinois, PATRICK J. FITZGERALD, and defendant JOHN HARRIS, and hisattorney, TERRY EKL, is made pursuant to Rule 11 of the Federal Rules of CriminalProcedure and is governed in part by Rule 11(c)(1)(C), as more fully set forth below. Theparties to this Agreement have agreed upon the following:
Charge in This Case
2.Count Four of the superseding indictment (“indictment”) in this case chargesdefendant with wire fraud, in violation of Title 18, United States Code, Sections 1343 and1346.3.Defendant has read the charge against him contained in Count Four of theindictment, and that charge has been fully explained to him by his attorney.4.Defendant fully understands the nature and elements of the crime with whichhe has been charged.
Charge to Which Defendant is Pleading Guilty
 
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5.By this Plea Agreement, defendant agrees to enter a voluntary plea of guiltyto Count Four of the indictment. Count Four charges defendant with participating in ascheme to commit wire fraud, including through the deprivation of honest services, inviolation of Title 18, United States Code, Sections 1343 and 1346.
Factual Basis
6.Defendant will plead guilty because he is in fact guilty of the charge containedin Count Four of the indictment. In pleading guilty, Defendant admits the following factsand that those facts establish his guilt beyond a reasonable doubt and constitute relevantconduct pursuant to Guideline §1B1.3:From approximately October 2008 to on or about December 9, 2008, in the NorthernDistrict of Illinois, Eastern Division, Defendant, together with co-defendant Rod Blagojevichand others, participated in a scheme to deprive the people of the State of Illinois of theirintangible right to the honest services of Defendant and Rod Blagojevich, in violation of Title18, United States Code, Sections 1343 and 1346.It was part of the scheme that beginning in or about October 2008, and continuinguntil on or about December 9, 2008, Rod Blagojevich (“Blagojevich”), with the assistanceof Defendant and others, sought to obtain financial benefits for Blagojevich and his wife, inreturn for the exercise of his duty under Illinois law to appoint a United States Senator to fillthe vacancy created by the election of Barack Obama as President of the United States. Attimes Defendant assisted Blagojevich’s efforts to carry out the scheme by suggesting meansby which Blagojevich could secure personal benefits for himself in exchange for appointing
 
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a United States Senator, conducting factual research relating to the scheme at Blagojevich’sdirection, and counseling Blagojevich on carrying out the scheme. At other times, Defendantexpressed opposition to Blagojevich’s efforts to enrich himself through his appointment of a United States Senator, and/or did not follow instructions from Blagojevich to assist in thoseefforts.Specifically, starting in December 2005 and continuing until December 2008,Defendant served as then Illinois Governor Rod Blagojevich’s Chief of Staff. Over thecourse of many months in 2008, Defendant participated in and was aware of discussionsinvolving Blagojevich and others about the possibility that Blagojevich might have the abilityto appoint someone to replace then-U.S. Senator Barack Obama if he won the generalelection for the President of the United States. By early October 2008, Defendantparticipated in regular conversations with Blagojevich about what personal benefitsBlagojevich could obtain in exchange for naming someone to the U.S. Senate seat shouldObama win the Presidency. As one example, around October 6, Blagojevich askedDefendant what Blagojevich could get in exchange for the U.S. Senate seat. Defendant toldBlagojevich that the appointment could either reward an ally or make a new ally but thatBlagojevich could not trade the Senate seat for something for himself. In other discussionswith Blagojevich, Defendant and others told Blagojevich that he could not receive money(either campaign money or other money) in exchange for naming someone to the Senate seat.Blagojevich ignored Defendant’s statements.
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