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USvsRita

USvsRita

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Published by: thepeopleagainstritacrundwell on Apr 19, 2012
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02/20/2014

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AO 91 (REV.5/85) Criminal Complaint
AUSA Joseph C. Pedersen (815) 987-4444
W44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444 
 
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
WESTERN DIVISION
UNITED STATES OF AMERICA
CRIMINAL COMPLAINT
v.CASE NUMBER:RITA A. CRUNDWELL
UNDER SEAL
I, the undersigned complainant, being duly sworn on oath, state that the following is true and correct to thebest of my knowledge and belief: From on or about September 1, 2011 to on or about March 31, 2012, at Dixon,in the Northern District of Illinois, Western Division RITA A. CRUNDWELL defendant herein:devised and intended to devise a scheme to defraud and to obtain money from the City of Dixon,Illinois by means of materially false and fraudulent pretenses, representations, and promises, andthat for the purpose of executing the aforesaid scheme to defraud and to obtain money by false andfraudulent pretenses, representations, and promises, and attempting to do so, on November 2, 2011,knowingly did cause to be transmitted by means of wire communication in interstate commercecertain signs and signals, namely, a funds transfer in the amount of $175,000 from the FederalReserve Bank in Saint Paul, Minnesota to the Federal Reserve Bank in Cincinnati, Ohio for creditto the account ending in the numbers 7503 held in the name of the City of Dixon at Fifth Third Bank in Dixon, Illinois;in violation of Title 18, United States Code, Section 1343. I further state that I am a Special Agent with the FederalBureau of Investigation, and that this complaint is based on the facts contained in the Affidavit which is attachedhereto and incorporated herein.
Signature of ComplainantPATRICK GARRYSpecial Agent, Federal Bureau of InvestigationSworn to before me and subscribed in my presence,April 13, 2012Dateat Rockford, IllinoisCity and StateP. MICHAEL MAHONEY, U.S. Magistrate JudgeName & Title of Judicial Officer Signature of Judicial Officer
 
 
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
WESTERN DIVISION
UNITED STATES OF AMERICA ))vs. ) No.) Magistrate JudgeRITA A. CRUNDWELL ) P. Michael Mahoney
 AFFIDAVIT IN SUPPORT OF COMPLAINT
I, PATRICK GARRY, being first duly sworn upon oath, depose and state:1. I am a Special Agent of the Federal Bureau of Investigation ("FBI")and have been so employed for the past six years. As part of my duties as anFBI Special Agent, I investigate criminal violations relating to white collarcrime, including mail, wire, and bank fraud. In addition, I have receivedspecialized training regarding the investigation of various financial offenses,assisted in such investigations, and am familiar with the types of transactionsconducted by those involved in illegal activities to disguise and conceal thenature of their dealings as well as their efforts to hide the proceeds generatedfrom these illegal activities to avoid detection. I have participated in theexecution of multiple federal search warrants.2. I have been assigned to the investigation into Rita A. Crundwellregarding a scheme to defraud the City of Dixon. Other FBI special agents haveparticipated in this investigation. I have discussed the results of their
 
investigation into this matter with other special agents. This affidavit is basedin part upon those discussions and in part upon my own investigation andobservations. This affidavit is submitted in support of a criminal complaintalleging that Rita A. Crundwell has violated Title 18, United States Code,Section 1343. Because this affidavit is being submitted for the limited purposeof establishing probable cause in support of a criminal complaint charging Rita A. Crundwell with wire fraud, I have not included each and every fact known tome concerning this investigation. I have set forth only the facts that I believeare necessary to establish probable cause to believe that the defendantcommitted the offense alleged in the complaint.3. As part of my duties and responsibilities as a Special Agent with theFBI, I have been involved in an investigation concerning the activities of Rita A.Crundwell ("Crundwell") who is believed to be involved in a scheme to defraudthe City of Dixon, Illinois. As part of the investigation, in late 2011, Iinterviewed James G. Burke in Rockford, Illinois. Burke stated the following:He is the mayor of the City of Dixon and has held that position since 1999. Rita A. Crundwell is employed as the Comptroller for the City of Dixon and has heldthat position since approximately the early 1980's. As Comptroller, Crundwellhandles all of the finances for the City of Dixon. Crundwell's salary asComptroller is $80,000 per year. Crundwell lives a luxurious lifestyle, has a
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