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SUPREME COURT : STATE OF NEW YORK COUNTY OF SUFFOLK
THE GOVERNMENT vs FRED TOWLE, JR., Defendant. ----------------------------------------x I, THOMAS J. SPOTA, District Attorney of Suffolk County, pursuant to the provisions of Article 195 of the Criminal Procedure Law, by this Superior Court Information, accuse the defendant FRED TOWLE, JR. of the crimes of: COUNT ONE BRIBE RECEIVING IN THE SECOND DEGREE, in violation of Section 200.11 of the New York State Penal Law, committed as follows: From on or about and between January 2002 and May 2003, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., a public servant, solicited, accepted, or agreed to accept any benefit, valued in excess of ten thousand dollars ($10,000.00), from another person upon an agreement or understanding that his vote, opinion, judgment, action, decision, or exercise of discretion as a public servant would thereby be influenced, to wit: the defendant, in Suffolk County, accepted in excess of ten thousand dollars ($10,000.00) from a person, whose identity is known to the Suffolk County District Attorney's Office, with the understanding that a portion thereof would be paid to the benefit of a public official, whose identity is known to the Suffolk County District Attorney's Office, in order to affect certain actions. COUNT TWO BRIBE RECEIVING IN THE SECOND DEGREE, in violation of Section 200.11 of the New York State Penal Law, committed as follows: From on or about and between January 2002 and May 2003, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., a public servant, solicited, accepted, or agreed to accept any benefit, valued in excess of ten thousand dollars ($10,000.00), from another person upon an agreement or understanding that his vote, opinion, judgment, action, decision, or exercise of discretion as a public servant would thereby be influenced, to wit: the defendant, in Suffolk County, accepted in excess of ten thousand dollars ($10,000.00) from a person, whose identity is known to the Suffolk County District Attorney's Office, with the understanding that a portion thereof would be paid to another person, whose identity is known to the Suffolk County District Attorney's Office, in order that certain actions would be affected. COUNT THREE BRIBE RECEIVING IN THE SECOND DEGREE, in violation of Section 200.11 of the New York State Penal Law, committed as follows: From on or about and between January 2002 and May 2003, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., a public servant, solicited, accepted, or agreed to accept any benefit,__ valued in excess of ten thousand dollars ($10,000.00), from another person upon an agreement or understanding that his vote, opinion, judgment, action, decision, or exercise of discretion as a public servant would thereby be influenced. COUNT FOUR BRIBE RECEIVING IN THE THIRD DEGREE, in violation of Section 200.10 of the New York State Penal Law, committed as follows: From on or about and between June 1996 and June 1997, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., as a public servant, solicited, accepted, or agreed to accept any benefit from another person upon an agreement or understanding that his vote, opinion, judgment, action, decision, or exercise of discretion as a public servant would thereby be influenced. COUNT FIVE MONEY LAUNDERING IN THE FOURTH DEGREE, in violation of Section 470.05(2) of the New York State Penal Law, committed as follows: The defendant FRED TOWLE, JR., acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, on or about and between January 2002 and May 2003, in Suffolk County, New York, knowing that the property involved in one or more financial transactions represented the proceeds of criminal conduct, namely Bribe Receiving in the Second Degree, transmitted and transferred, on one or more occasions, monetary instruments which in fact represent the proceeds of Bribe Receiving in the Second Degree with the intent to promote the carrying on of criminal conduct, and the total value of such monetary instruments exceeded ten thousand dollars ($10,000.00). COUNT SIX DEFRAUDING THE GOVERNMENT, in violation of Section 195.20 of the New York State Penal Law, committed as follows: From on or about and between January 1996 and may 2003, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., acting in concert with others, whose identities are known to the Suffolk County District Attorney's Office, as public servants, engaged in a scheme constituting a systematic ongoing course of conduct with intent to defraud the state or a political subdivision of the state or a governmental instrumentality within the state, or to obtain property from the state or a political subdivision of the state or a governmental instrumentality within the state by false or fraudulent pretenses, representations or promises, and so obtained property with a value in excess of one thousand dollars ($1,000.00) from such state, political subdivision, or governmental instrumentality. COUNT SEVEN RECEIVING UNLAWFUL GRATUITIES, in violation of Section 200.35 of the New York State Penal Law, committed as follows: The defendant FRED TOWLE, JR., from on or about and between January 2001 and May 2003, in the County of Suffolk, State of New York, agreed to accept a benefit for having engaged in official conduct which he was required or authorized to perform and for which he was not entitled to any special or additional compensation, to wit: the defendant, after engaging in official legislative duties relating to real property in Suffolk County, accepted cash and personal property from others whose identities are known to the Suffolk County District Attorney's Office. COUNT EIGHT SCHEME TO DEFRAUD IN THE FIRST DEGREE, in violation of Section New York State Penal Law, committed as follows: defendant FRED TOWLE, JR., acting in concert with identities are known to the Suffolk County District 190.65 of the others, whose Attorney's office, from on or about and between May 1998 and May 2003, in Suffolk County, New York, engaged in a scheme constituting a systematic ongoing course of conduct by soliciting campaign contributions with intent to obtain such contributions from ten or more persons by the false fraudulent pretense that said funds would be used for legitimate campaign expenses and so obtained funds from one or more persons. The scheme further involved causing the filing of Board of Elections Disclosure Statements for the Friends of Fred Towle, Jr. and Citizens for Fred Towle Committees, which to disclose the expenditure of campaign funds for Fred Jr.'s personal benefit and the personal benefit of others, are known to the Suffolk County District to wit: the defendant, acting in concert with known to the Suffolk County District kept for his personal use cash fund raising events, raffles, and `-50 50/50"-fund raising activities; used __campaign credit and failed Towle, whose identities Attorney's Office, others, whose identities are Attorney's Office, accepted and intended to be used for entry to ATM/debit cards and campaign committee checks for personal expenses not related to legitimate campaign activities; caused Election Board and Suffolk County Ethics Commission Disclosure Statements to be falsely filed; and caused Suffolk County employees, whose identities are known to the Suffolk County District Attorney's Office, to perform campaign work while on County time and being paid by Suffolk County. COUNT NINE OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: On or about July 15, 2002. The defendant Fred Towle, Jr. , in the County of Suffolk, State of New York, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, caused the filing of a false written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority did present it to a public office, public servant, or public authority with the knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public office, public servant, or public authority, to wit: the defendant, while acting in convert with another, whose identity is known to the Suffolk County District Attorney's Office, caused the filing of a false written instrument, namely a Board of Elections Disclosure Statement, filed on behalf of the Citizens for Fred Towle, Jr. Committee with the Suffolk County Board of Elections. COUNT TEN FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in 'violation of Section 175.10 of the New York State Penal Law, committed as follows: On or about July 15, 2002, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, and with the intent to defraud, prevented the making of a true entry or caused the omission thereof in the business records of an enterprise, namely the Citizens for Fred Towle, Jr., in order to aid or conceal the commission of another crime. COUNT ELEVEN OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: On or about January 15, 2002, the defendant FRED TOWLE, JR., in the County of Suffolk, State of New York, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority, did present it to a public office, public servant, or public authority with the knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public office, public servant, or public authority, to wit: the defendant, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's office, caused the filing of a false written instrument, namely a Board of Elections Disclosure Statement, filed on behalf of the Citizens for Fred Towle, Jr. Committee with the Suffolk County Board of Elections. COUNT TWELVE FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Section 175.10 of the New York State Penal Law, committed as follows: On or about January 15, 2002, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, and with the intent to defraud, prevented the making of a true entry or caused the omission thereof in the business records of an enterprise, namely the Citizens for Fred Towle, Jr., in order to aid or conceal the commission of another crime. COUNT THIRTEEN OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: On or about October 4, 2001, the defendant FRED TOWLE, JR, in the County of Suffolk, State of New York, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's office, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority, did present it to a public office, public servant, or public authority with the knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public office, public servant, or public authority, to wit: the defendant, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, caused the filing of a false written instrument, namely a Board of Elections Disclosure Statement, filed on behalf of the Citizens for Fred Towle, Jr. Committee with the Suffolk County Board of Elections. COUNT FOURTEEN FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Section 175.10 of the New York State Penal Law, committed as follows: On or about October 4, 2001, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, and with the intent to defraud, prevented the making of a true entry or caused the omission thereof in the business records of an enterprise, namely the Citizens for Fred Towle, Jr., in order to aid or conceal the commission of another crime. COUNT FIFTEEN OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: On or about July 15, 2001, the defendant FRED TOWLE, JR., in the County of Suffolk, State of New York, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's office, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority, did present it to a public office, public servant, or public authority with the knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public office, public servant, or public authority, to wit: the defendant, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, caused the filing of a false written instrument, namely a Board of Elections Disclosure Statement, filed on behalf of the Citizens for Fred Towle, Jr. Committee with the Suffolk County Board of Elections. COUNT SIXTEEN FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Section 175.10 of the New York State Penal Law, committed as follows: On or about July 15, 2001, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, and with the intent to defraud, prevented the making of a true entry or caused the omission thereof in the business records of an enterprise, namely the Citizens for Fred Towle, Jr., in order to aid or conceal the commission of another crime. COUNT SEVENTEEN OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: On or about July 15, 2001, the defendant FRED TOWLE, JR., in the County of Suffolk, State of New York, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority, did present it to a public office, public servant, or public authority with the knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public office, public servant, or public authority, to wit: the defendant, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, caused the filing of a false written instrument, namely a Board of Elections Disclosure Statement, filed on behalf of the Friends of Fred Towle, Jr. Committee with the Suffolk County Board of Elections. COUNT EIGHTEEN FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Section 175.10 of the New York State Penal Law, committed as follows: On or about July 15, 2001, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, and with the intent to defraud, prevented the making of a true entry or caused the omission thereof in the business records of an enterprise, namely the Friends of Fred Towle, Jr., in order to aid or conceal the commission of another crime. COUNT NINETEEN OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: On or about January 15, 2001, the defendant FRED TOWLE, JR., in the County of Suffolk, State of New York, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority, did present it to a public office, public servant, or public authority with the knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public authority, to wit: the defendant, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, caused the filing of a false written instrument, namely a Board of Elections Disclosure Statement, filed on behalf of the Friends of Fred Towle, Jr. Committee with the Suffolk County Board of Elections. COUNT TWENTY IN THE FIRST DEGREE, in violation of FALSIFYING BUSINESS RECORDS Section 175.10 follows: On or about January 15, 2001, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, and with the intent to defraud, prevented the making of a true entry or caused the omission thereof in the business records of an enterprise, namely the Friends of Fred Towle, Jr., in order to aid or conceal the commission of another crime. COUNT TWENTY-ONE OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: On or about July 15, 2000, the defendant FRED TOWLE, JR., in the County of Suffolk, State of New York, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority, did present it to a public office, public servant, or public authority with the knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public office, public servant, or public authority, to wit: the defendant, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, caused the filing of a false written instrument, namely a Board of Elections Disclosure Statement, filed on behalf of the Friends of Fred Towle, Jr. Committee with the Suffolk County Board of Elections. COUNT TWENTY-TWO FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of ,Section 175.10 of the New York State Penal Law, committed as follows: On or about July 15, 2000, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, and with the intent to defraud, prevented the making of a true entry or caused the omission thereof in the business records of an enterprise, namely the Friends of Fred Towle, Jr., in order to aid or conceal the commission of another crime. COUNT TWENTY-THREE OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: On or about January 15, 2000, the defendant FRED TOWLE, JR., in the County of Suffolk, State of New York, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority, did present it to a public office, public servant, or public authority with the knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public office, public servant, or public authority, to wit: the defendant, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, caused the filing of a false written instrument, namely a Board of Elections Disclosure Statement, filed on behalf of the Friends of Fred Towle, Jr. Committee with the Suffolk County Board of Elections. COUNT TWENTY-FOUR FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Section 175.10 of the New York State Penal Law, committed as follows: On or about January 15, 2000, in the County of Suffolk, State of New York, the defendant FRED TOWLE JR., while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, and with the intent to defraud, prevented the making of a true entry or caused the omission thereof in the business records of an enterprise, namely the Friends of Fred Towle, Jr., in order to aid or conceal the commission of another crime. COUNT TWENTY-FIVE OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section committed as follows: On or about October 22, 1999, the JR., in the County of Suffolk, State of New concert with another, whose identity is known to the Suffolk County District Attorney's Office, knowing that a written instrument contained a false statement or false information, and with intent or any political subdivision or public it to a public office, public servant, or the knowledge or belief that it would be or recorded in, or otherwise become a part of the records of such public office, public servant, or public authority, to wit: the defendant, while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, caused the filing of a false written instrument, namely a Board of Elections Disclosure Statement, filed on of the Friends of Fred Towle, Jr. Committee with the Suffolk Board of Elections. COUNT TWENTY-SIX FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Section 175.10 of the New York State Penal Law, committed as follows: On or about October 22, 1999, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, and with the intent to defraud, prevented the making of a true entry or caused the omission thereof in the business records of an enterprise, namely the Friends of Fred Towle, Jr., in order to aid or conceal the commission of another crime. COUNT TWENTY-SEVEN OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: On or about July County of Suffolk, the defendant FRED TOWLE, JR., in the County of Suffolk, Sate of New York, while acting in concert with another, whose identity is known to the Suffolk County knowing that a written instrument false statement or false information, and with intent the state or any political subdivision or public it to a public office, public servant, or the knowledge or belief that it would be or recorded in, or otherwise become a part of the records of such public office, public authority, to wit: the defendant, while acting in concert with another, whose identity is know to the Suffolk County District Attorney's Office, casued the filing of a false written instrument, namely a Board of Elections Disclosure Statement, filed on behalf of the Friends of Fred Towle, Jr. Committee with the Suffolk County Board of Elections. COUNT TWENTY-EIGHT FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Section 175.10 of the New York State Penal Law, committed as follows: On or about July 15, 1999, in the County of Suffolk, State of New York, the defendant FRED TOWLE, JR., while acting in concert with another, whose identity is known to the Suffolk County District Attorney's Office, and with the intent to defraud, prevented the making of a true entry or caused the omission thereof in the business records of an enterprise, namely the Friends of Fred Towle, Jr., in order to aid or conceal the commission of another crime. COUNT TWENTY-NINE OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: On or about January 15, 1999, the defendant FRED TOWLE, JR., in the County of Suffolk, State of New York, while acting in concert with another, whose identity is known to the Suffolk County District-.Attorney's Office knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any authority, did present public authority with the knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public office, public servant, or authority, to wit: the defendant, while another, whose identity is known to the Suffolk County District Attorney's office, caused the filing of a false written instrument, namely a Board of Elections Disclosure Statement, filed on behalf of the Friends of Fred Towle, Jr. Committee with the Suffolk County Board of Elections. COUNT THIRTY IN THE FIRST DEGREE, in violation of Section 175.10 of the New York State Penal Law, committed as follows: On or about January 15, 1999, in the County of Suffolk, York, the defendant FRED TOWLE, JR., while acting in another, whose identity is known to the Suffolk County and with the intent to defraud, entry or caused the omission thereof enterprise, namely the Friends of aid or conceal the commission of another crime. COUNT THIRTY-ONE OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: From on or about and between May and June 2002, the defendant FRED TOWLE, JR., in the County of Suffolk, State of New York, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority or public benefit corporation of the state, offered or presented it to a public office, public servant, public authority, or public benefit corporation, with knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public office, public servant, public authority, or public benefit corporation, to wit: the defendant offered or presented a County of Suffolk Financial Disclosure Statement to the Suffolk County Ethics Commission knowing that it omitted income derived from the Citizens for Fred Towle Committee, which income was required to be disclosed pursuant to the Suffolk County Financial Disclosure Law, Local Law No. 12-1978. COUNT THIRTY-TWO OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: From on or about and between may and June 2001, the defendant FRED TOWLE, JR., in the County of Suffolk, State of New York, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority or public benefit corporation of the state, offered or presented it to a public office, public servant, public benefit corporation, with knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public office, public servant, public authority, or public benefit corporation, to wit: the defendant offered or presented a County of Suffolk Financial Disclosure Statement to the Suffolk County Ethics Commission knowing that it omitted income derived from the Friends of Fred Towle, Jr. Committee, which was required to be disclosed pursuant to the Suffolk Financial Disclosure Law, Local Law No. 12-1978. COUNT THIRTY-THREE OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: From on or about and between May and June 2000, the defendant FRED TOWLE, Jr., in the County of Suffolk, State of New York, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority, or public benefit corporation, with knowledge or belief that it would be filed with registered or recorded in, or otherwise become a part of the records of such public office, public authority, or public benefit corporation, to wit: the defendant offered or presented a County of Suffolk Financial Disclosure Statement to the Suffolk County Ethics Comission knowing that it omitted income derived from the Friends of Fredd Towle, Jr. Committee, which income was required to be disclosed pursuant ot the Suffolk County Financial Disclosure Law, Local Law No. 12-1978. COUNT THIRTY-FOUR OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: From on or about and between May and June 1997, the defendant FRED TOWLE, JR., in the County of Suffolk, State of New York, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority or public benefit corporation of the state, offered or presented it to a public office, public servant, public authority, or public benefit corporation, with knowledge or belief that it would be filed with, or otherwise become a part of the records of such public office, public servant, public authority, or wit: the defendant offered or presented a County of Suffolk Financial Disclosure Statement to the Suffolk County Ethics Commission knowing that it omitted income derived from the Friends of Fred Towle, Jr Commiztee, which income- was required to be disclosed pursuant to the Suffolk County Financial Disclosure Law, Local Law No. 12-1978. COUNT THIRTY-FIVE OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in violation of Section 175.35 of the New York State Penal Law, committed as follows: From on or about and between May and June 1996, the defendant FRED TOWLE, JR., in the County of Suffolk, State of New York, knowing that a written instrument contained a false statement or false information, and with intent to defraud the state or any political subdivision or public authority or public benefit corporation of the state, offered or presented it to a public office, public servant, public authority, or public benefit corporation, with knowledge or belief that it would be filed with, registered or recorded in, or otherwise become a part of the records of such public office, public servant, public authority, or public benefit corporation, to wit: the defendant offered or presented a County of Suffolk Financial Disclosure Statement to the Suffolk County Ethics Commission knowing that it omitted income derived from the Friends of Fred Towle, Jr. Committee, which income was required to be disclosed pursuant to the Suffolk County Financial Disclosure Law, Local Law No. 12-1978. Dated: Riverhead, New York May 28, 2003 THOMAS J. SPOTA District Attorney Suffolk County |
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