Complaint Ausas Margaret J
AO 91 (REV.5/85) Criminal Complaint AUSAs Margaret J. Schneider (312) 353-1875, Michael T. Donovan (312) 886-2035, Brandon D. Fox (312) 353-5277 W44444444444444444444444444444444444444444444444444444444444444444444444444444444444444444 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA CRIMINAL COMPLAINT v. CASE NUMBER: DEAN NICHOLS, REGGI HOPKINS, ELLIOTT KOZEL, UNDER SEAL ANTHONY JOHNSON, MARY SMITH, REGINA HOLLIE, and BRYANT JESSUP I, the undersigned complainant, being duly sworn on oath, state that the following is true and correct to the best of my knowledge and belief: COUNT ONE From in or about September 2011 to no later than February 2012, at Oak Park and Chicago, in the Northern District of Illinois, Eastern Division DEAN NICHOLS and REGGI HOPKINS, defendants herein: conspired to commit an offense against the United States, specifically bribery of a public official (18 U.S.C. § 201(b)(1)), by agreeing to directly and indirectly, corruptly give, offer and promise a thing of value, namely money, to a purported Health and Human Services (“HHS”) official, with the intent to influence that official’s awarding of HHS grants; in violation of Title 18, United States Code, Section 371. COUNT TWO From in or about September 2011 to no later than November 2011, at Oak Park and Chicago, in the Northern District of Illinois, Eastern Division DEAN NICHOLS and ELLIOTT KOZEL, defendants herein: conspired to commit an offense against the United States, specifically bribery of a public official (18 U.S.C. § 201(b)(1)), by agreeing to directly and indirectly, corruptly give, offer and promise a thing of value, namely money, to a purported HHS official, with the intent to influence that official’s awarding of HHS grants; in violation of Title 18, United States Code, Section 371.
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