4

irniTED STATES DISTRICT COURT

'

DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA ) Crim. No.

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) Violations:

) 18 U.S.C. 1951 (Hobbs Act Extortion/Conspiracy)

) 18 U.S.C. 2 (Aiding & Abetting)
) 18 U.S.C. 981 and 28 U.S.C. 2461

V.

) (ExtortionForfeiture)

(1)KENNETH BRISSETTE and

(2)TIM0THY SULLIVAN
Defendants.

)
)
)

FIRST SUPERSEDING INDICTMENT

The Grand Jury charges that:

At all times material to this Indictment:

1.

Starting inorabout January 2014, defendant TIMOTHTV SULLIVAN

("SULLIVAN"), aresident ofBoston, Massachusetts, was employed as the Chiefof Staff for
Intergovernmental Relations/Senior Advisor for External Relations for the City ofBoston.
2.

Starting in or about May 2014, defendant KENNETH BRISSETTE

("BRISSETTE"), aresident ofBoston, Massachusetts, was employed as the Director ofthe

Office ofTourism, Sports and Entertainment for the City ofBoston. The mission ofthe Office
ofTourism, Sports and Entertainment is to promote all public events inthe City ofBoston. As

part ofthat mission, the Office ofTourism, Sports and Entertainment assists companies and
individuals seeking to stage events in Boston, including music and sports performances,

filmmaking, etc., including assistance in securing pennits to use atpublic areas inBoston.
3.

The Intemational Alliance of Theatrical Stage Employees ("lATSE"), Local 11

("Local 11"), was a labor organization that represented over 200 employees including