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The complaint is split in two parts, the first dealing with evidence of corruption prior to October and the second more recent evidence including recent tape recordings of the governor concerning Wrigley Field and the appointment of a replacement to fill Barack Obama's Senate seat.
Among the key points in the criminal complaint:
- Citations of testimony in the trial of former Blagojevich fundraiser Antoin "Tony" Rezko, who was convicted last June of using his influence with the governor to launch a $7 million kickback scheme.
- Document confirms that Rezko has been discussing what testimony he could provide in return for a reduced sentence, and cites some of his statements:
"Rezko has proffered with the government in hopes of receiving a recommendation from the government for a reduced sentence. During the proffer sessions, Rezko at times has provided accounts that differ from those of other witnesses - but in broad terms Rezko's account incriminates Rod Blagojevich in a 'pay to play' criminal scheme."
- The complaint cites testimony from Rezko's trial by Joseph Cari, a former key fundraiser for Al Gore's presidential campaign who has pleaded guilty to attempted extortion of a company wanting to gain state business:
"Rod Blagojevich informed Cari that it was easier for governors to solicit campaign contributions" because governors had the ability to 'award contracts' and give legal work, consulting work, and investment banking work to campaign contributors. Rod Blagojevich informed Cari that Rezko and (key campaign fundraiser Chris) Kelly were his point people in raising campaign contributions.
The complaint also cites an Illinois Health Facilities Planning Board vote to allow Mercy Hospital to build a hospital, with votes being changed at the last minute:
"Rezko has admitted that he manipulated the Mercy vote based on Mercy's agreement to make a contribution to Rod Blagojevich, which agreement he states was communicated to Rod Blagojevich."
- The second part of the complaint begins by citing evidence of efforts to obtain campaign contributions in return for receipt of state business before a tougher law on donations takes effect Jan. 1.:
"According to Individual A, after Individual B left the meeting on October 6, 2008, Rod Blagojevich told Individual A that he was going to make an upcoming announcement concerning a $1.8 billion project involving the Tollway Authority. Rod Blagojevich told Individual A that Lobbyist 1 was going to approach Highway Contractor 1 to ask for $500,000 for Friends of Blagojevich. Rod Blagojevich told Individual A that, 'I could have made a larger announcement but wanted to see how they perform by the end of the year. If they don't perform, (expletive) 'em.'
"According to Individual A, on October 8, 2008, during a discussion of fundraising from various individuals and entities, the discussion turned to Children's Memorial Hospital, and Rod Blagojevich told Individual A words to the effect of 'I'm going to do $8 million for them. I want to get (Hospital Executive 1) for 50.'"
-That apparently referred to his desire to get a $50,000 campaign contribution from the CEO of Children's and get the hospital $8 million in state money "through some type of pediatric care reimbursement."
- Blagojevich then indicated her was considering "rescinding his commitment of state funds to benefit Children's Memorial Hospital because Hospital Executive 1 has not made a recent campaign contribution to Rod Blagojevich."
- In a telephone call on Dec. 3, 2008 with a lobbyist, Blagojevich praised a lobbyist for telling a contributor that a contribution had to be made now, in connection with a proposed law that was awaiting signature on the governor's desk. It was believed to be a law that would direct some casino revenue to the horse racing industry. "Good" and "good job," Blagojevich is quoted as telling the lobbyist.
- During a conversation with the president of an engineering firm that has received more than $10 million in state business between fiscal years 2004 and 2008, the governor thanks the businessman for his support (apparently $60,000 from a recent fundraiser hosted by the businessman). "I want to thank you again for your support and friendship and we are going to do everything we can to get that capital bill," the governor says about a proposed that would benefit companies like the one run by the businessman.
Allegations Blagojevich tried to get members of the Chicago Tribune editorial board fired by threatening to withhold state aide regarding Wrigley Field, which is owned by the same company.
- Blagojevich and Chief of Staff John Harris "are corruptly using and threatening to use the powers (of the governor's office) ... to fire Chicago Tribune editorial board members who were responsible for editorials sharply critical of Rod Blagojevich's actions as Governor and ... calling for his impeachment."
- The Tribune Company considered financial help from the Illinois Finance Authority related to the financing or sale of Wrigley Field. Blagojevich told Harris to inform a Tribune executive that the company's "sale of Wrigley Field would not be forthcoming unless members of the Chicago Tribune's editorial board were fired."
- On Nov. 3, Blagojevich's wife, Patti, was recorded in the background telling the governor to tell an aide "to hold up that (expletive) Cubs (expletive)...(expletive) them." She later said the Tribune owner can "just fire" the writers in question.
- Blagojevich told an aide on Nov. 4 that "our recommendation is fire all those (expletive) people, get 'em the (expletive) out of there and get us some editorial support."
Allegations of a scheme to trade his power to appoint someone to fill Barack Obama's Senate seat for personal gain:
- "Rod Blagojevich has been intercepted conspiring to trade the Senate seat for particular positions that the President-elect has the power to appoint (e.g. the Secretary of Health and Human Services)."
_ Blagojevich also was heard working to "sell the Senate seat in exchange for his wife's placement on paid corporate boards" or him getting a job at a private foundation "in a significant position with a substantial salary."
_ He also talked about getting campaign contributions "upfront in consideration of an appointment."
_ Blagojevich told an aide that if he wasn't going to get anything in return, if "they're not going to offer anything of any value, then I might just take it."
_ Again threatening to appoint himself to the job, Blagojevich said, "unless I get something real good, (expletive), I'll just send myself, you know what I'm saying."
_ "I'm going to keep this Senate option for me a real possibility, you know, and therefore, I can drive a hard bargain. You hear what I'm saying. And if I don't get what I want and I'm not satisfied with it, then I'll just take the Senate seat myself."
- Blagojevich described the Senate seat as "a (expletive) valuable thing, you just don't give it away for nothing."
_ The governor talked about the difficulties of negotiating a trade. The "trick ... is how do you conduct indirectly ... a negotiation."
_ Blagojevich compared himself to a sports agent working for a client: "How much are you offering, (President-elect)? What are you offering, (Senate Candidate 2)? ... Can always go to ... (Senate Candidate 3)."
- The governor said he would make the appointment in good faith, but "it is not coming for free. ... It's got to be good stuff for the people of Illinois and good for me. ... (President-elect), you want it? Fine. But it's got to be good or I could always take (the Senate seat)."
- Of the power to appoint the Senate replacement: "I've got this thing and it's (expletive) golden, and, uh, uh, I'm just not giving it up for (expletive) nothing. I'm not gonna do it. And, and I can always use it. I can parachute me there."
- "I want to make money," in the range of $250,000 to $300,000, he was quoted as saying of the need for a new job.
- The complaint indicates that the governor spent considerable time over the past month "weighing the option of appointing himself to the open Senate seat, and has expressed a variety of reasons for doing so, including frustration at being 'stuck' as governor, a belief that he will be able to obtain greater resources if he is indicted as a sitting Senator as opposed to a sitting governor, and a desire to remake his image in consideration of a possible run for President in 2016, avoid impeachment by the Illinois legislature, make corporate contacts that would be of value to him after leaving public office, facilitate his wife's employment as a lobbyist, and assist in generating speaking fees should he decide to leave public office."