Charges Against Sheldon Silver
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COUNT ONE
1. From at least in or about 2000, up to and including
the date of this Complaint, in the Southern District of New York and
elsewhere, SHELDON SILVER, the defendant, willfully and knowingly,
having devised and intending to devise a scheme and artifice to
defraud, and to deprive the public of its intangible right to SILVER' s
honest services as an elected legislator and as the Speaker of the
New York State Assembly, would and did transmit and cause to be
transmitted by means of wire communication in interstate and foreign
commerce, writings, signs, signals, pictures, and sounds for the
purpose of executing such scheme and artifice, to wit, SILVER used
the power and influence of his official position to obtain for himself
millions of dollars in bribes and kickbacks masked as legitimate
income earned by SILVER as a private lawyer.
(Title 18, United States Code, Sections 1343 and 1346.)
COUNT TWO
2. From at least in or about 2000, up ·to and including
the date of this Complaint, in the Southern District of New York and
elsewhere, SHELDON SILVER, the defendant, willfully and knowingly,
having devised and intending to devise a scheme and artifice to
defraud, and to deprive the public of its intangible right to SILVER' s
honest services as an elected legislator and as the Speaker of the
New York State Assembly, for the purpose of executing such scheme
and artifice and attempting to do so, placed in a post office and
authorized depository for mail matter, a matter and thing to be sent
and delivered by the Postal Service and deposited and caused to be
deposited a matter and thing to be sent and delivered by private and
commercial interstate carrier, and took and received therefrom, such
matter and thing, and knowingly caused to be delivered by mail and
such carrier according to the direction thereon, such matter and
thing, to wit, SILVER used the power and influence of his official
position to obtain for himself millions of dollars in bribes and
kickbacks masked as legitimate income earned by SILVER as a private
lawyer.
(Title 18, United States Code, Sections 1341 and 1346.)COUNT THREE
3. From at least in or about 2000, up to and including
the date of this Complaint, in the Southern District of New York and
elsewhere, SHELDON SILVER, the defendant, and others known and
unknown, willfully and knowingly did combine, conspire, confederate,
and agree together and with each other to commit honest services mail
fraud in violation of Title 18, United States Code, Sections 1341
and 1346.
4. It was a part and an object of the conspiracy that
SHELDON SILVER, the defendant, willfully and knowingly, having
devised and intending to devise a scheme and artifice to defraud,
and to deprive the public of its intangible right to SILVER' s honest
services as an elected legislator and as the Speaker of the New York
State Assembly, for the purpose of executing such scheme and artifice
and attempting to do so, placed in a post office and authorized
depository for mail matter, a matter and thing to be sent and
delivered by the Postal Service and deposited and caused to be
deposited a matter and thing to be sent and delivered by private and
2 commercial interstate carrier, and took and received therefrom, such
matter and thing, and knowingly caused to be delivered by mail and
such carrier according to the direction thereon, such matter and
thing, in violation of Title 18, United States Code, Sections 1341
and 1346, to wit, SILVER agreed with others known and unknown,
including a co-conspirator not named herein ("CC-1"), to use the
power and influence of his official position to induce certain real
estate developers with significant business before the State of New
York to retain the law firm of CC-1 in exchange for hundreds of
thousands of dollars in secret bribes and kickbacks paid to SILVER
by the law firm, which were masked as legitimate income earned by
SILVER as a private lawyer.
(Title 18, United States Code, Section 1349.)