SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

CYRUS R.VANCE, JR.,

DISTRICT ATTORNEY OF NEW YORK
COUNTY,

Plaintiff-Claiming Authority,

-against-
JOHN F. HAGGERTY, Jr. VERIFIED COMPLAINT
SPECIAL ELECTION OPERATIONS, LLC
Index No.
Criminal Defendants.

The Plaintiff-Claiming Authority, CYRUS R. VANCE, JR., District Attorney of New York

County (Plaintiff), by his undersigned attorney, as and for his Verified Complaint, alleges

upon information and belief, as follows:

1. At all times relevant hereto, Plaintiff was and continues to be the duly elected District

Attorney of New York County, with offices located at One Hogan Place, City of New York,

County and State of New York.

2. Venue is proper in this County pursuant to Civil Practice Law and Rules ("CPLR")

section 1311(10)(b), in that a criminal prosecution has commenced against JOHN F. HAGGERTY,

Jr. AND SPECIAL ELECTION OPERATIONS (the defendants), in New York County, for the

crimes of Grand Larceny in the First Degree in violation of Penal Law Section 155.42, a class B

felony, Money Laundering in the Second Degree in violation of Penal Law Section 470.15, a class

C felony, and, and Falsifying Business Records in the First Degree, in violation of Penal Law

Section 175.10, a class E felony, and related crimes.

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 3. This investigation involves, among other things, transactions between (a) New York

City Mayor Michael R. Bloomberg (Bloomberg), (b) the Independence Party (the Party) and

(c) Special Election Operations (SEO) and its proprietor, John F. Haggerty, Jr. (Haggerty).

4. SEO is a limited liability company organized in New York State.

5. Haggerty is the sole member and owner of SEO.

6. Haggerty is a political operative who volunteered on the Bloombergs 2009 campaign

for re-election (the Campaign).

7. Haggerty devised a scheme to steal Bloombergs money by making false

representations to Bloombergs agents and the Campaign staff.

8. Haggerty falsely represented the contours and expenses of and Election Day Operation

that he claimed he would organize, plan and run under the auspices of the Party.

9. In direct reliance upon Haggertys misrepresentations to Bloombergs agents and the

Campaign staff, Bloomberg paid the Party $1,200,000.00 (One Million Two Hundred Thousand

Dollars), $100,000 (One Hundred Thousand Dollars) of which was a contribution to the Party.

10. The vast majority of services outlined in the Election Day Operation presented by

Haggerty and on which Bloombergs agents relied were never performed.

11. Haggerty falsely told various persons that these services were performed.

12. Haggerty obscured the ownership and control of SEO as part of his illegal scheme.

13. Haggerty produced false documents in the form of bank checks in an attempt to cover

up his crime.

14. Haggerty stole $1,100,000.00 (One Million One Hundred Thousand Dollars) from

Bloomberg.

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 15. The defendants as a result of their criminal activity generated approximately

$1,100,000.00 (One Million One Hundred Thousand Dollars) in total criminal proceeds.

16. Haggerty used much of the stolen funds to purchase a home located at 115 Greenway

North in Forest Hills, New York.

17. This amount constitutes the proceeds, substituted proceeds, and/or

instrumentalities of the felony crimes of Grand Larceny in the First Degree in violation of Penal

Law Section 155.42, a class B felony, Money Laundering in the Second Degree in violation of

Penal Law Section 470.15, a class C felony, and Falsifying Business Records in the First Degree,

in violation of Penal Law Section 175.10, a class E felony, and related crimes, and/or of any

criminal activity arising from a common scheme or plan of which these crimes form a part.

18. The defendants in this case are jointly and severally liable, because SEO was an

instrument wholly owned and controlled by Haggerty and used by him to facilitate the crimes

committed.

FIRST CAUSE OF ACTION

19. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1

through 18 above with the same force and effect as though the same were set forth fully herein.

20. By virtue of the conduct set forth in paragraphs 1 through 18 above, the defendants have

committed the crimes of Grand Larceny in the Second Degree in violation of Penal Law Section

155.42, a class B felony, Money Laundering in the Second Degree in violation of Penal Law

Section 470.15, a class C felony, and Falsifying Business Records in the First Degree, in violation

of Penal Law Section 175.10, a class E felony, and related crimes, and/or of any criminal

activity arising from a common scheme or plan of which these crimes form a part, which

constitute felony crimes under New York State law.

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 21. Through the defendants commission of the felony crimes referred to and described in

Paragraphs 1 through 18 above, the defendants have obtained property which constitutes the

proceeds of a crime and/or the substituted proceeds of a crime within the meaning of CPLR

Article 13-A.

22. The proceeds and/or substituted proceeds referred to in the immediately preceding

paragraph have an approximate value of $1,100,000.00 (One Million One Hundred Thousand

Dollars).

23. By virtue of the foregoing, the defendants are liable, jointly and severally, to the

plaintiff, in his capacity as Claiming Authority, for forfeiture of the property specified above.

SECOND CAUSE OF ACTION

24. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1

through 23 above with the same force and effect as though the same were set forth fully herein.

25. By virtue of the conduct set forth in paragraphs 1 through 18 above, the defendants have

committed the crimes of Grand Larceny in the First Degree in violation of Penal Law Section

155.42, a class B felony, Money Laundering in the Second Degree in violation of Penal Law

Section 470.15, a class C felony, and Falsifying Business Records in the First Degree, in violation

of Penal Law Section 175.10, a class E felony and related crimes, and/or of any criminal activity

arising from a common scheme or plan of which these crimes form a part, which constitute felony

crimes under New York State law.

26. Through the criminal defendants commission of the felony crimes referred to and

described in Paragraphs 1 through 18 above, the defendants have obtained property which

constitutes the instrumentality of a crime within the meaning of CPLR Article 13-A.

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 27. The instrumentality referred to in the immediately preceding paragraph has an

approximate value of $1,100,000.00 (One Million One Hundred Thousand Dollars).

28. By virtue of the foregoing, the defendants are liable, jointly and severally, to the

plaintiff, in his capacity as Claiming Authority, for forfeiture of the property specified above

THIRD CAUSE OF ACTION

29. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1

through 28 above with the same force and effect as though the same were set forth fully herein.

30. By virtue of the conduct set forth in paragraphs 1 through 18 above, the criminal

defendants have committed the crimes of Grand Larceny in the First Degree in violation of Penal

Law Section 155.42, a class B felony, Money Laundering in the Second Degree in violation of

Penal Law Section 470.15, a class C felony, and Falsifying Business Records in the First Degree,

in violation of Penal Law Section 175.10, a class E felony, and related crimes, and/or of any

criminal activity arising from a common scheme or plan of which these crimes form a part,

which constitute felony crimes under New York State law.

31. Through the defendants commission of the felony crimes referred to and described in

Paragraphs 1 through 18 above, the defendant Haggerty has obtained property which constitutes the

substituted proceeds of a crime within the meaning of CPLR Article 13-A.

32. The substituted proceeds referred to in the immediately preceding paragraph is

defendant Haggertys real estate located at 115 Greenway North, Forest Hills, New York.

33. By virtue of the foregoing, defendant Haggerty is liable to the plaintiff, in his capacity

as Claiming Authority, for forfeiture of the property specified above.

FOURTH CAUSE OF ACTION

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 34. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1

through 33 above, with the same force and effect as though the same were set forth fully herein.

35. By virtue of the foregoing, the defendants are liable, jointly and severally, to the

plaintiff, in his capacity as Claiming Authority, for a money judgment in the amount of

$1,100,000.00 (One Million One Hundred Thousand Dollars) , pursuant to CPLR Article 13-A

for forfeiture of the property specified above.

WHEREFORE, Plaintiff demands that judgment be entered against defendants

JOHN F. HAGGERTY. Jr. AND SPECIAL ELECTION OPERATIONS (the defendants), as

follows:

a) As to the First Cause of Action directing the forfeiture of property having a

value of $1,100,000.00 (One Million One Hundred Thousand Dollars) as specified

in said cause of action;

b) As to the Second Cause of Action directing the forfeiture of property having

a value of $1,100,000.00 (One Million One Hundred Thousand Dollars), as

specified in said cause of action;

c) As to the Third Cause of Action directing the forfeiture of real estate located

at 115 Greenway North, Forest Hills, New York.

d) As to the Fourth Cause of Action directing the entry of a money judgment in

the amount of $1,100,000.00 (One Million One Hundred Thousand Dollars).

DATED: June 14, 2010 Cyrus R. Vance, Jr.,

New York, New York District Attorney, New York County
Plaintiff-Claiming Authority

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 By:
____________________________________
Tara Christie Miner - (212) 335-4114
Assistant District Attorney
Attorney for Plaintiff-Claiming Authority
One Hogan Place
New York, New York 10013

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STATE OF NEW YORK )
) SS.:
COUNTY OF NEW YORK )

TARA CHRISTIE MINER, being duly sworn, states that she is an Assistant District

Attorney, of counsel to CYRUS R. VANCE, JR., District Attorney in and for the County of

New York, the Plaintiff-Claiming Authority ("Plaintiff") in this action, and that the foregoing

Verified Complaint is true to her own knowledge, except as to matters therein stated on information

and belief, and as to those matters she believes to be true; that the grounds for her belief as to all

matters not stated upon her knowledge are her review of documents in the possession of the District

Attorney's Office; and that the reason why the verification is not made by the plaintiff is that he is a

public officer.

____________________________________
TARA CHRISTIE MINER
Assistant District Attorney
Attorney for Plaintiff-Claiming Authority
Office and Post Office Address
One Hogan Place
New York, New York 10013
(212) 335-4114

Notary Public
Sworn to me this day of June, 2010

______________________________

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

CYRUS R. VANCE, JR.,

DISTRICT ATTORNEY OF NEW YORK COUNTY

Plaintiff-Claiming Authority,

-against-

JOHN F. HAGGERTY, Jr.

SPECIAL ELECTION OPERATIONS

Criminal-defendants.

VERIFIED COMPLAINT

Index No.

Cyrus R. Vance, Jr.,

District Attorney
New York County
One Hogan Place
New York, New York 10013
(212) 335-9000