RECEWER.. Complaint AUSA Sean Franzblau (312) 353-5305 MAR 04 mis UNITED STATES DISTRICT COURT BRUTON NORTHERN DISTRICT OF ILLINOIS ek Ue bBrRercourT EASTERN DIVISION UNITED STATES OF AMERICA 1 9 1 CASE rom CR _€ v. UNDER SE: | MAGISTRATE sug VALDEE CRIMINAL COMPLAINT DONALD LUSTER, and WILL WILEY I, the complainant in this case, state that the following is true to the best of my knowledge and belief, From in or around November 2017 to in or around January 2018, at Harvey, in the Northern District of Illinois, Bastern Division, and elsewhere, the defendant(s)s violated: Code Section Offense Description ‘Title 18, United States Code, Section 371 did _knowingly agree and conspire to commit an offense against the United States, that is, for an agent ofa local government that received $10,000 or more in federal benefits in any one year period to corruptly solicit, demand, accept, and agree to accept, anything of value from any person, intending to be influenced or rewarded in connection with any business, transaction, or series of transactions of such local government involving anything of value of $5,000 or more, in violation of Title 18, United States Code, Section a)(1XB); This criminal complaint is based upon these facts: X_ “Continued on the attached sheet, ‘NIJIKA RUSTAGI Special Agent, Federal Bureau of Investigation Sworn to before me and signed in my presenee. h Wana, Date: March % 2019 - Tudge’s signlure City and state: Chicago, Illinois MARIA VALDEZ, U.S. Magistrate Judge ‘Printed name and TitleUNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS | AEFIDAVIT I, NUJIKA RUSTAGI, being duly sworn, state as follows: I. Introduction 1. Tama Special Agent with the Federal Bureau of Investigation, and have been so employed since approximately December 2017. My current responsibilities include the investigation of public corruption offenses, including bribery and rewards coneérning programs receiving federal benefits, in violation of Title 18, United States Code, Section 666(a). As part of my duties, I have been involved in various types of electronic surveillance, the preparation and execution of search warrants, as well as in the debriefing of defendants, witnesses, informants and others who have knowledge of criminal activities. Through my work as an FBI Special Agent, I have become familiar with the means and methods of those engaged in corruption-related offenses. I have been involved in the investigation of DONALD LUSTER and WILL WILEY concerning their involvement in violations of federal law, including violations of Title 18, United States Code, Section 371. 3. | This affidavit is submitted in support of a criminal complaint alleging that DONALD LUSTER and WILL WILEY have violated Title 18, United States Code, Section 371, Because this affidavit is being submitted for the limited purpose of establishing probable cause in support of a:criminal complaint charging LUSTERand WILEY with conspiring to commit an offense against the United States, that is, for an agent of a local government that received $10,000 or more in federal benefits in any one year period to corruptly solicit, demand, accept, and agree to accept, anything of value from any person, intending to be influenced or rewarded in connection with any business, transaction, or series of transactions of such local government involving anything of value of $5,000 or more, in violation of Title 18, United States Code, Section 666(a)(1)(B), I have not included each and every fact known to me concerning this investigation. I have set forth only the facts that I believe are necessary to establish probable cause to believe that the defendants committed the offense alleged in the complaint, 4, The information contained in this affidavit is based on my participation in this investigation; my review of preliminary transcripts and summaries of. court- authorized interceptions of wire communications and consensually recorded conversations; witness interviews; review of records obtained from various parties; discussions with other law enforcement agents with knowledge of this investigation; my training and experience; and the training and experience of other law enforeement officers with whom I have consulted. Since this affidavit is being submitted for the limited purpose of establishing probable cause as set forth herein, I have not included each and every fact known to me concerning this investigation. 5. This affidavit includes summaries of court-authorized interceptions of wire communications and consensually recorded conversations, as well as my understanding of certain such conversations which are set forth in brackets. My