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Razzouk Complaint

Razzouk Complaint

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Published by City Room

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Published by: City Room on Jan 25, 2011
Copyright:Attribution Non-commercial


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RAB:DDBF.#2010R01746UNITED STATES DISTRICT COURTEASTERN DISTRICT OF NEW YORK- - - - - - - - - - - - - - - -XUNITED STATES OF AMERICA-against-SASSINE RAZZOUK,Defendant.- - - - - - - - - - - - - - - -X
AFFIDAVIT IN SUPPORT OFARREST WARRANT(18 U.S.C. § 666(a)(1)(B))EASTERN DISTRICT OF NEW YORK, SS:EVAN CAMPANELLA, being duly sworn, deposes and saysthat he is a Special Agent with the United States Immigration andCustoms Enforcement (“ICE”), duly appointed according to law andacting as such.Upon information and belief, there is probable cause tobelieve that from in or about and between January 2008 andDecember 2010, within the Eastern District of New York andelsewhere, the defendant SASSINE RAZZOUK, being an agent of anorganization that received in excess of $10,000 in any one-yearperiod under a Federal program involving a grant, subsidy orother form of Federal assistance, did knowingly, intentionallyand corruptly solicit, demand, accept and agree to acceptsomething of value, to wit: United States currency, with theintent to be influenced and rewarded in connection with businessand a series of transactions of such organization involving$5,000 or more.
2(Title 18, United States Code, Section 666(a)(1)(B))The source of your deponent’s information and thegrounds for his belief are as follows:
1. I have been a Special Agent with ICE since May2007. I am currently assigned to ICE’s El Dorado Task Force,which investigates money laundering.2.The facts set forth in this affidavit are basedupon my own investigation, a review of documents, witnessinterviews, and information I have learned from other agencies,including the Internal Revenue Service (“IRS”) and the Office ofthe Inspector General of the Port Authority of New York and NewJersey.I.The Defendant, Con Ed and the Contractor3. Consolidated Edison of New York, Inc. (“Con Ed”) isa New York-based corporation that provides electric, gas
andsteam utility services in New York City and Westchester County.As a provider of such utility services, Con Ed is responsible forthe construction, maintenance and repair of its electric, gas andsteam systems. As a part of its electric system, Con Edconstructs and maintains various facilities, including generatingstations, and transmission and distribution substations. Con Ed
Because the purpose of this affidavit is only to state theprobable cause to arrest, I have not described all the relevantfacts, circumstances and conversations of which I am awarerelated to this investigation. All conversations and statementsreported in this affidavit, unless directly quoted, are describedin substance and in part.
3received federal funding in excess of $10,000 for each year from2008 through 2010.4.The defendant SASSINE RAZZOUK has been employed atCon Ed since 1984. He has been a Section Manager in Con Ed’sElectrical/Control Systems Design section since 2003. In thisposition, RAZZOUK oversaw the design of electrical controlsystems within Con Ed’s generating stations and substations,which included the preparation of project specifications, thereview of bids and technical proposals, the awarding of contractsto design/engineering contractors and the approval of payments tothese contractors.
 5. In awarding contracts for the design of theelectrical controls systems for its electrical facilities, Con Edmade selections from a pre-qualified group of contractors.Specific contracts were then awarded based on the technicalqualifications of the contractor to perform the specific projectrequirements and the contractor’s bid amount. In accordance withCon Ed procurement procedures, among the contractors who met the
A confidential source (“CS”) who has been employed at Con Edfor the last thirty years, and from April 2009 through thepresent served as a director in the internal auditing unit,provided me with much of the information contained hereinregarding Con Ed and RAZZOUK’s employment at Con Ed. The CS’sduties include conducting internal audits and investigations ofCon Ed’s operations, which include the contracts overseen by thedefendant SASSINE RAZZOUK.

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