I, Robert J. Cooke, being duly sworn, state the following is true and correct to the best of my
knowledge and belief.
From in or about March 2009 to in or about May 2009, in Hudson County, in the District of New
Jersey and elsewhere, defendant
LAVERN WEBB-WASHINGTON
and others, to include JC Official 1 and the Consultant, did knowingly and willfully conspire to obstruct,
delay, and affect interstate commerce by extortion under color of official right, by accepting and
agreeing to accept corrupt payments that were paid and to be paid by another, with that person’s
consent, in exchange for defendant Lavern Webb-Washington’s future official assistance in Jersey City
Government matters.
I further state that I am a Special Agent with the Federal Bureau of Investigation, and that this
complaint is based on the following facts:
SEE ATTACHMENT A
2
"contributions" from a "developer" - a reference to the CW - who
would give the Consultant the money and the Consultant would give
it to Webb-Washington, according to the Consultant.
3
call, among other things, JC Official 1 and the Consultant agreed
that things had gone well at the meeting that day. The
Consultant and JC Official 1 discussed plans for the CW and
agreed, per the Consultant, “Let’s get him to give . . . three
candidates [including defendant Webb-Washington] money. . . .”
4
told JC Official 1 that the Consultant had called others,
including defendant Webb-Washington, who would arrive at the
diner at 12:30 p.m. Regarding defendant Webb-Washington and
others who were scheduled to meet them at various times that day,
JC Official 1 said, “Let’s spread them out fifteen minutes
difference, okay?” The Consultant agreed and asked JC Official
1: “How are we operating this? [They] are coming into the
restaurant to see [the CW]?” JC Official 1 responded, “Yes they
are coming in to see [the CW] and then whatever conversation you
want and then they’ll leave.” The Consultant agreed and then
asked JC Official 1, “And then how are we dealing with the
money?” JC Official 1 responded to the Consultant that they
would “talk to [the CW] about the money.” JC Official 1
[laughing] then stated that, like he had said before, “they don’t
get any money” [meaning that JC Official 1 did not want to
discuss the passing of payments to these individuals, including
defendant Webb-Washington, over the telephone].
5
that zone change,” prompting defendant Webb-Washington to
reiterate, “You don’t have to worry.” Defendant Webb-Washington
and the CW then exchanged contact information before defendant
Webb-Washington drove away.
6
Defendant Webb-Washington further remarked to the CW that she had
“common sense” and it did not take “nine degrees” to make her do
the “right thing.” Responding to the CW’s request not to forget
the CW in July, defendant Webb-Washington said that the CW did
not have to say this anymore and that she “got” the CW. As the
conversation concluded, defendant Webb-Washington further
remarked that the CW had her “back,” and she had the CW’s back.