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Blagojevich Complaint

Blagojevich Complaint

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A 76-page federal complaint outlining bribery and conspiracy charges against Illinois Gov. Rod Blagojevich and his chief of staff, John Harris.
A 76-page federal complaint outlining bribery and conspiracy charges against Illinois Gov. Rod Blagojevich and his chief of staff, John Harris.

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Published by: Washington Post Investigations on Dec 10, 2008
Copyright:Attribution Non-commercial

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03/05/2013

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 AO 91 (REV.5/85) Criminal Complaint
AUSAs: REID SCHAR (353-8897), CARRIE HAMILTON (353-4558), and CHRIS NIEWOEHNER (353-6117
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION
UNITED STATES OF AMERICA
UNDER SEAL
V.CRIMINAL COMPLAINTROD R. BLAGOJEVICH, andJOHN HARRISI, the undersigned complainant being duly sworn state the following is true and correct to the best of myknowledge and belief.
Count One
From in or about 2002 to the present, in Cook County, in the Northern District of Illinois, defendants did,conspire with each other and with others to devise and participate in a scheme to defraud the State of Illinois andthe people of the State of Illinois of the honest services of ROD R. BLAGOJEVICH and JOHN HARRIS, infurtherance of which the mails and interstate wire communications would be used, in violation of Title 18, UnitedStates Code, Sections 1341,1343, and 1346; all in violation of Title 18 United States Code, Section 1349.
Count Two
Beginning no later than November 2008 to the present, in Cook County, in the Northern District of Illinois,defendants ROD R. BLAGOJEVICH and JOHN HARRIS, being agents of the State of Illinois, a State governmentwhich during a one-year period, beginning January 1, 2008 and continuing to the present, received federal benefitsin excess of $10,000, corruptly solicited and demanded a thing of value, namely, the firing of certain ChicagoTribune editorial members responsible for widely-circulated editorials critical of ROD R. BLAGOJEVICH,intending to be influenced and rewarded in connection with business and transactions of the State of Illinoisinvolving a thing of value of $5,000 or more, namely, the provision of millions of dollars in financial assistance bythe State of Illinois, including through the Illinois Finance Authority, an agency of the State of Illinois, to theTribune Company involving the Wrigley Field baseball stadium; in violation of Title 18, United States Code,Sections 666(a)(1)(B) and 2.
 
I further state that I am a Special Agent of the Federal Bureau of Investigation and that this complaint is basedon the following facts:SEE ATTACHED AFFIDAVIT Continued on the attached sheet and made a part hereof: X Yes No Daniel W. Cain, Special AgentFederal Bureau of InvestigationSworn to before me and subscribed in my presence,December 7, 2008 at Chicago, IllinoisDate City and StateMICHAEL T. MASON, United States Magistrate JudgeName & Title of Judicial Officer Signature of Judicial Officer
 
 Northern District of Illinois))
UNDER SEAL
County of Cook, City of Chicago)
AFFIDAVIT IN SUPPORT OF APPLICATION
I, Daniel W. Cain, hereinafter referred to as “Affiant,” being duly sworn, state asfollows:
I.INTRODUCTION
1.I am a Special Agent with the Federal Bureau of Investigation (FBI) assignedto the Chicago, Illinois Field Division. I have been a Special Agent with the FBI for over twenty-two years. I am presently assigned to the West Resident Agency of the FBI's ChicagoField office. My duties include investigating corruption of public officials, mail fraud, wirefraud, and other white collar crimes. I have been involved in white collar crimeinvestigations for a majority of my career as a Special Agent with the FBI.2.I have participated in and am familiar with this investigation through interviewsand analysis of reports submitted by other Special Agents of the FBI, the Internal RevenueService (IRS), the U.S. Postal Inspection Service (USPIS), and the U.S. Department of Labor's Office of Inspector General (DOLIG); personal interviews conducted with witnesses;my review of consensually-recorded conversations; a review of pen register information, trapand trace information, and telephone toll record information; and a review of informationderived from the interception of wire communications occurring to and from certaintelephones. I also am familiar with information derived from the interception of oralcommunications occurring in the offices of Friends of Blagojevich, 4147 North Ravenswood

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