Professional Documents
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Plaintiff-Claiming Authority,
-against-
JOHN F. HAGGERTY, Jr. VERIFIED COMPLAINT
SPECIAL ELECTION OPERATIONS, LLC
Index No.
Criminal Defendants.
The Plaintiff-Claiming Authority, CYRUS R. VANCE, JR., District Attorney of New York
County (Plaintiff), by his undersigned attorney, as and for his Verified Complaint, alleges
1. At all times relevant hereto, Plaintiff was and continues to be the duly elected District
Attorney of New York County, with offices located at One Hogan Place, City of New York,
2. Venue is proper in this County pursuant to Civil Practice Law and Rules ("CPLR")
section 1311(10)(b), in that a criminal prosecution has commenced against JOHN F. HAGGERTY,
Jr. AND SPECIAL ELECTION OPERATIONS (the defendants), in New York County, for the
crimes of Grand Larceny in the First Degree in violation of Penal Law Section 155.42, a class B
felony, Money Laundering in the Second Degree in violation of Penal Law Section 470.15, a class
C felony, and, and Falsifying Business Records in the First Degree, in violation of Penal Law
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3. This investigation involves, among other things, transactions between (a) New York
City Mayor Michael R. Bloomberg (Bloomberg), (b) the Independence Party (the Party) and
(c) Special Election Operations (SEO) and its proprietor, John F. Haggerty, Jr. (Haggerty).
8. Haggerty falsely represented the contours and expenses of and Election Day Operation
that he claimed he would organize, plan and run under the auspices of the Party.
Campaign staff, Bloomberg paid the Party $1,200,000.00 (One Million Two Hundred Thousand
Dollars), $100,000 (One Hundred Thousand Dollars) of which was a contribution to the Party.
10. The vast majority of services outlined in the Election Day Operation presented by
11. Haggerty falsely told various persons that these services were performed.
12. Haggerty obscured the ownership and control of SEO as part of his illegal scheme.
13. Haggerty produced false documents in the form of bank checks in an attempt to cover
up his crime.
14. Haggerty stole $1,100,000.00 (One Million One Hundred Thousand Dollars) from
Bloomberg.
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15. The defendants as a result of their criminal activity generated approximately
$1,100,000.00 (One Million One Hundred Thousand Dollars) in total criminal proceeds.
16. Haggerty used much of the stolen funds to purchase a home located at 115 Greenway
instrumentalities of the felony crimes of Grand Larceny in the First Degree in violation of Penal
Law Section 155.42, a class B felony, Money Laundering in the Second Degree in violation of
Penal Law Section 470.15, a class C felony, and Falsifying Business Records in the First Degree,
in violation of Penal Law Section 175.10, a class E felony, and related crimes, and/or of any
criminal activity arising from a common scheme or plan of which these crimes form a part.
18. The defendants in this case are jointly and severally liable, because SEO was an
instrument wholly owned and controlled by Haggerty and used by him to facilitate the crimes
committed.
19. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1
through 18 above with the same force and effect as though the same were set forth fully herein.
20. By virtue of the conduct set forth in paragraphs 1 through 18 above, the defendants have
committed the crimes of Grand Larceny in the Second Degree in violation of Penal Law Section
155.42, a class B felony, Money Laundering in the Second Degree in violation of Penal Law
Section 470.15, a class C felony, and Falsifying Business Records in the First Degree, in violation
of Penal Law Section 175.10, a class E felony, and related crimes, and/or of any criminal
activity arising from a common scheme or plan of which these crimes form a part, which
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21. Through the defendants commission of the felony crimes referred to and described in
Paragraphs 1 through 18 above, the defendants have obtained property which constitutes the
proceeds of a crime and/or the substituted proceeds of a crime within the meaning of CPLR
Article 13-A.
22. The proceeds and/or substituted proceeds referred to in the immediately preceding
paragraph have an approximate value of $1,100,000.00 (One Million One Hundred Thousand
Dollars).
23. By virtue of the foregoing, the defendants are liable, jointly and severally, to the
plaintiff, in his capacity as Claiming Authority, for forfeiture of the property specified above.
24. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1
through 23 above with the same force and effect as though the same were set forth fully herein.
25. By virtue of the conduct set forth in paragraphs 1 through 18 above, the defendants have
committed the crimes of Grand Larceny in the First Degree in violation of Penal Law Section
155.42, a class B felony, Money Laundering in the Second Degree in violation of Penal Law
Section 470.15, a class C felony, and Falsifying Business Records in the First Degree, in violation
of Penal Law Section 175.10, a class E felony and related crimes, and/or of any criminal activity
arising from a common scheme or plan of which these crimes form a part, which constitute felony
26. Through the criminal defendants commission of the felony crimes referred to and
described in Paragraphs 1 through 18 above, the defendants have obtained property which
constitutes the instrumentality of a crime within the meaning of CPLR Article 13-A.
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27. The instrumentality referred to in the immediately preceding paragraph has an
28. By virtue of the foregoing, the defendants are liable, jointly and severally, to the
plaintiff, in his capacity as Claiming Authority, for forfeiture of the property specified above
29. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1
through 28 above with the same force and effect as though the same were set forth fully herein.
30. By virtue of the conduct set forth in paragraphs 1 through 18 above, the criminal
defendants have committed the crimes of Grand Larceny in the First Degree in violation of Penal
Law Section 155.42, a class B felony, Money Laundering in the Second Degree in violation of
Penal Law Section 470.15, a class C felony, and Falsifying Business Records in the First Degree,
in violation of Penal Law Section 175.10, a class E felony, and related crimes, and/or of any
criminal activity arising from a common scheme or plan of which these crimes form a part,
31. Through the defendants commission of the felony crimes referred to and described in
Paragraphs 1 through 18 above, the defendant Haggerty has obtained property which constitutes the
defendant Haggertys real estate located at 115 Greenway North, Forest Hills, New York.
33. By virtue of the foregoing, defendant Haggerty is liable to the plaintiff, in his capacity
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34. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1
through 33 above, with the same force and effect as though the same were set forth fully herein.
35. By virtue of the foregoing, the defendants are liable, jointly and severally, to the
plaintiff, in his capacity as Claiming Authority, for a money judgment in the amount of
$1,100,000.00 (One Million One Hundred Thousand Dollars) , pursuant to CPLR Article 13-A
follows:
c) As to the Third Cause of Action directing the forfeiture of real estate located
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By:
____________________________________
Tara Christie Miner - (212) 335-4114
Assistant District Attorney
Attorney for Plaintiff-Claiming Authority
One Hogan Place
New York, New York 10013
7
STATE OF NEW YORK )
) SS.:
COUNTY OF NEW YORK )
TARA CHRISTIE MINER, being duly sworn, states that she is an Assistant District
Attorney, of counsel to CYRUS R. VANCE, JR., District Attorney in and for the County of
New York, the Plaintiff-Claiming Authority ("Plaintiff") in this action, and that the foregoing
Verified Complaint is true to her own knowledge, except as to matters therein stated on information
and belief, and as to those matters she believes to be true; that the grounds for her belief as to all
matters not stated upon her knowledge are her review of documents in the possession of the District
Attorney's Office; and that the reason why the verification is not made by the plaintiff is that he is a
public officer.
____________________________________
TARA CHRISTIE MINER
Assistant District Attorney
Attorney for Plaintiff-Claiming Authority
Office and Post Office Address
One Hogan Place
New York, New York 10013
(212) 335-4114
Notary Public
Sworn to me this day of June, 2010
______________________________
Plaintiff-Claiming Authority,
-against-
Criminal-defendants.
VERIFIED COMPLAINT
Index No.