Excerpts From the Complaint

Here are a couple for gems which GA plucked from the complaint.  But first, a few thoughts.

Several things popped out at me upon first reading.

One,  that Ricciaridi is STILL covering for 'people' (on page 8) when he gives THIS as a motive for his "spying":  to determine whether his job was secure.  You can see how he's setting up his own defense.

GA calls bulshit on that.  No way.

Why did he have to collect thousands of emails and forward them to persons GA suspects are political operatives and/or the Mayor's opponents?  What does that have to do with assessing job security?  Further, Ricciardi didn't need an Archive file to "spy"- he had access to EVRYONE'S email account and could  have read them ANYTIME without making an 'Archive'.

Given how the complaint is framed (page 4) as occurring in the context of a divided political culture, there is no doubt that the Feds are not buying the Ricciardi motive.  They know it's  about politics.  And you can bet the prosecutor will be going there. And likely produce all sorts of evidence to show that Ricciardi was engaged in a political operation, a conspiracy.

GA would advise Ricciardi to come totally clean.  You are dealing with people much smarter than yourself.  And your friends wont 'have your back," in the Big House.  There you'll be too busy worrying about the 'new friends' at your backside to worry about your old friends.

Another point of note is the role of the "blogs" in the complaint, citing them as evidence of the political schism in Hoboken.   

GA believes this points to to Hoboken411.com, Perry Klaussen and Lane Bajardi for their handling of leaked emails and other leaked materials as part of the conspiracy.  It also points to the other political blogs- whose  emails were requested on the Mason- Russo resolution: Hoboken Journal,  Mile Square View and Grafix Avenger.  

And the Resolution (email jihad) was the 'cover' to out the illegally obtained emails by Ricciardi and forwarded to others.

 

GA is chomping at the bit to talk to the Feds. Maybe over a falafel at Mamoun's.  Whadaya say?

Now for some excerpts from the complaint:

 page 4

7. The investigation has also revealed that many of the elected and appointed officials in the City retain strong ties to the previous administration or are otherwise politically opposed to the Mayor, and have sparred with the current Mayor on a variety of municipal issues, large and small. These officials include several members of the City Council, as well as high-ranking employees of different City municipal agencies, such as Public Safety Department, the Fire
Department, and the OEM.

8. Evidence of this schism in the City is apparent through the postings of articles and comments on City-related issues to different weblogs, or "blogs."

page 5

10. During the course of the Security Audit, the private company identified an e-mail archive file (the "Archive File") on the hard drive of defendant RICCIARDI's work computer.

11. The Archive File contained copies of e-mails that had been sent to the Mayor's e-mail account and to the e-mail accounts of certain Mayor's Office Employees.

15. The Security Audit also revealed that someone had configured software so that all e-mails that arrived in the Mayor's inbox would be automatically downloaded from the Mayor's e-mail account to the Archive File.

16. This configuration intercepted e-mails as they were being sent, and placed them in the Archive File.

page 6

D. THE E-MAILS ARE FORWARDED TO OTHERS

20. The Security Audit also revealed that e-mails stored in the Archive File had been forwarded to at least two different accounts:

a. One recipient e-mail accountbelongedtoIndividuall.aCity municipal official (the "Individual 1 E-Mail Account").

b. A second recipient e-mail account belonged to Individual 2, a former City municipal official (the "Individual 2 E-Mail Account").

E. INDIVIDUAL 3 HANDS OVER AN E-MAIL

21. The Individual 1 E-Mail Account and the Individual 2 E-Mail Account are not the only email accounts that have obtained e-mails from the Mayor's e-mail account without the Mayor's knowledge or consent.

22. On or about May 18,2011, Individual 3, a City municipal employee, came into the Mayor's office and provided - to certain Mayor's Office Employees - a hard copy of an e-mail that Individual 3 received from defendant RICCIARDI's personal e-mail account on or about February 1,2011 (the "February 1 RICCIARDI E-Mail").

page 7

27. Moreover, law enforcement investigation has now has confirmed that an e-mail account linked to the Archive File contained Intercepted E-Mails, which had been sent to the Individual 1

E-Mail Account, the Individual 2 E-Mail Account, and the Individual 3 E-Mail Account. Neither Individual 1, Individual 2, Individual 3, or defendant RICCIARDI were parties to any of the Intercepted E-Mails.

28. The topics of the Intercepted E-Mails related to City business.

G. DEFENDANT RICCIARDI CONFESSES TO LAW ENFORCEMENT2

29. On or about May 25,2011, Special Agents of the FBI interviewed defendant RICCIARDI at his home. During the course of a lengthy conversation with the FBI, defendant RICCIARDI admitted to creating the Archive File and forwarding intercepted e-mails to others. Specifically, defendant RICCIARDI admitted that:

page 8

e. Defendant RICCIARDI created the Archive File, and then directed the Intercepted E-Mails to the Archive File, so that he could "spy" on the Mayor and the Mayor's Office Employees, and determine whether his job was secure.

f. Defendant RICCIARDI forwarded certain Intercepted E-Mails to Individual 1 and Individual 2 at the request of Individual 1 and Individual 2.