Here it is. (pdf file)
In order to conceal the expenditure and conversion of State resources for the benefit of political campaigns, defendant implemented a procedure by which employee salaries were paid in part by HRCC and by the use of compensatory leave. Defendant awarded compensatory leave to certain Minority Leaderâ€™s Office staff in order for those staff members to work on political campaigns while on paid absences from the State. Those employees were not authorized to use such compensatory leave for purposes other than campaign work. Defendant knew that the partial HRCC payments and the compensatory leave did not fully account for the campaign work performed by State employees.
Defendant also knew and it was reasonably foreseeable to him that State employees, supervised by defendant, submitted travel vouchers to the State in which the employees falsely claimed travel expenses accrued as official State business, when in truth and in fact, the employeesâ€™ travel was related to political campaigns. Defendant signed, and thereby approved, such travel vouchers, including a voucher that caused the State to mail payment to a State employee on or about June 8, 2000. […]
In or about 2000, in the Northern District of Illinois and elsewhere, defendant did knowingly conspire with Roger Stanley and others known and unknown to commit extortion affecting commerce, namely to obtain money from a Real Estate Partnership, with the partnershipâ€™s consent, having induced said consent under color of official right. […]
Roger Stanley, a partner of the Real Estate Partnership, agreed to provide, and did provide, a consulting job paid by the Partnership to an individual campaigning as a Republican candidate for a Illinois House seat in downstate Illinois (Candidate A). The purpose of the consulting job was to generate necessary income for Candidate A while Candidate A was campaigning for office. In connection with the campaign assistance to Candidate A, defendant TRISTANO agreed to assist the Villageâ€™s efforts to obtain the State grants, and did in fact recommend, as Chief of Staff to the Minority Leader, that discretionary grant funds be awarded to the Village. The State awarded to the Village approximately $1.3 million in grants funding the real estate development in or about 2000. […]