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Friday, December 12, 2008

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U.S. Senate

http://news.lp.findlaw.com/hdocs/docs/crim/ilgovblagojevich1208cmp.pdf

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 COMPLAINT

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

The state Canvassing Board this morning has convened and will scrutinize rejected absentee ballots cast for the Nov. 4 contest.


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