UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION
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.
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.
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
TEXT OF CRIMINAL COMPLAINT