Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
3Activity
0 of .
Results for:
No results containing your search query
P. 1
Haggerty Verified Complaint Final

Haggerty Verified Complaint Final

Ratings: (0)|Views: 200 |Likes:

More info:

Published by: Eliot Brown / New York Observer on Jun 14, 2010
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as DOC, PDF, TXT or read online from Scribd
See more
See less

06/14/2010

pdf

text

original

 
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK CYRUS R.VANCE, JR.,DISTRICT ATTORNEY OF NEW YORK COUNTY,Plaintiff-Claiming Authority,-against-JOHN F. HAGGERTY, Jr.SPECIAL ELECTION OPERATIONS, LLCCriminal Defendants.VERIFIED COMPLAINTIndex No.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, allegesupon information and belief, as follows:1.At all times relevant hereto, Plaintiff was and continues to be the duly elected DistrictAttorney of New York County, with offices located at One Hogan Place, City of New York,County and State 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 thecrimes 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 LawSection 175.10, a class “E” felony, and related crimes.1
 
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”).4.SEO is a limited liability company organized in New York State.5.Haggerty is the sole member and owner of SEO.6.Haggerty is a political operative who volunteered on the Bloomberg’s 2009 campaignfor re-election (“the Campaign”).7.Haggerty devised a scheme to steal Bloomberg’s money by making falserepresentations to Bloomberg’s agents and the Campaign staff.8.Haggerty falsely represented the contours and expenses of and Election Day Operationthat he claimed he would organize, plan and run under the auspices of the Party.9. In direct reliance upon Haggerty’s misrepresentations to Bloomberg’s agents and theCampaign staff, Bloomberg paid the Party $1,200,000.00 (One Million Two Hundred ThousandDollars), $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 byHaggerty and on which Bloomberg’s agents relied were never performed.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) fromBloomberg.2
 
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 North in Forest Hills, New York.17.This amount constitutes the proceeds,“substituted proceeds,and/or “instrumentalities” of the felony crimes of Grand Larceny in the First Degree in violation of PenalLaw 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 anycriminal 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 aninstrument wholly owned and controlled by Haggerty and used by him to facilitate the crimescommitted.FIRST CAUSE OF ACTION19.Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1through 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 havecommitted the crimes of Grand Larceny in the Second Degree in violation of Penal Law Section155.42, a class “B” felony, Money Laundering in the Second Degree in violation of Penal LawSection 470.15, a class “C” felony, and Falsifying Business Records in the First Degree, in violationof Penal Law Section 175.10, a class “E” felony, and related crimes, and/or of any criminalactivity arising from a common scheme or plan of which these crimes form a part, whichconstitute felony crimes under New York State law.3

Activity (3)

You've already reviewed this. Edit your review.
1 hundred reads
1 thousand reads

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->