(This is the first page of the criminal complaint against Gov. Rod Blagojevich and John Harris. It was posted 12-19-08, but has been back-dated to bump it off the front page. Some emphasis has been added. Mentioned on this page: conspiracy from 2002 to present, The Chicago Tribune and Tribune editorial members; Wrigley Field; )
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION
UNDER SEAL ---------
CRIMINAL COMPLAINT
UNITED STATES OF AMERICA
V.
ROD R. BLAGOJEVICH, and
JOHN HARRIS
I, the undersigned complainant being duly sworn state the following is true and correct to the best of my knowledge 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 and the people of the State of Illinois of the honest services of ROD R. BLAGOJEVICH and JOHN HARRIS, in furtherance of which the mails and interstate wire communications would be used, in violation of Title 18, United States 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 government which during a one-year period, beginning January 1, 2008 and continuing to the present, received federal benefits in excess of $10,000, corruptly solicited and demanded a thing of value, namely, the firing of certain Chicago Tribune 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 Illinois involving a thing of value of $5,000 or more, namely, the provision of millions of dollars in financial assistance by the State of Illinois, including through the Illinois Finance Authority, an agency of the State of Illinois, to the Tribune 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 based on the following facts:
SEE ATTACHED AFFIDAVIT
Continued on the attached sheet and made a part hereof: X Yes No
Daniel W. Cain, Special Agent
Federal Bureau of Investigation
Sworn to before me and subscribed in my presence,
December 7, 2008 at Chicago, Illinois
(Date, City and State)
MICHAEL T. MASON, United States Magistrate Judge
(Name & Title of Judicial Officer Signature of Judicial Officer)
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