" ! HOUSE OF REPRESENTATIVES 

111TH CONGRESS

1st Session 

REVIEW 

09–9

OFFICE OF CONGRESSIONAL ETHI

UNITED STATES HOUSE OF 

REPRESENTATIVES 

————— 

Report and Findings 

Transmitted to the 

Committee on Standards of Official Conduct 

on August 6, 2009 

and released publicly pursuant to H. Res. 895 of th

110th Congress as amended 

August 2009 


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ouse of Representatives Office of Congressional Ethics Review No. 09 9812


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09–
U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

75–661 

" ! HOUSE OF REPRESENTATIVES 

111TH CONGRESS

1st Session 

REVIEW 

2009

09–9

OFFICE OF CONGRESSIONAL ETHI

UNITED STATES HOUSE OF 

REPRESENTATIVES 

————— 

Report and Findings 

Transmitted to the 

Committee on Standards of Official Conduct 

on August 6, 2009 

and released publicly pursuant to H. Res. 895 of th

110th Congress as amended 

August 2009 


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(II) 

OFFICE OF 

CONGRESSIONAL ETHICS 

BOARD 

UNITED STATES HOUSE OF REPRESENTATIVES

ONE HUNDRED ELEVENTH CONGRESS

DAVID SKAGGS, Chair 

PORTER GOSS, Co-Chair 

YVONNE BURKE 

KAREN ENGLISH 

ALLISON HAYWARD 

JAY EAGEN 

WILLIAM FRENZEL 

ABNER MIKVA 

Leo J. Wise, Chief Counsel & Staff Director 

Omar Ashmawy, Investigative Counsel 


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REPORT 

Review No. 09–9812 

The Board of the Office of Congressional Ethics (he

‘‘Board’’), by a vote of no less than four members, on July 24

adopted the following report and findings and ordered them 

transmitted to the Committee on Standards of Official Con

the United States House of Representatives. 

SUBJECT: Representative Jesse Jackson, Jr. 

NATURE OF THE ALLEGED VIOLATION: Transcripts 

cordings of former Illinois Governor Rod Blagojevich contain 

ments that an ‘‘emissary’’ from Representative Jackson had 

to raise money for Blagojevich and provide ‘‘money up-fr

Blagojevich nominated Representative Jackson to the Illino

ate seat vacated by President Obama. If this ‘‘emissary’’ ac

ther at the direction of Representative Jackson or with his 

edge or acquiescence, Representative Jackson may have v

federal law and House rules. 

In the course of conducting this review, the OCE learne

staff resources of the Representative’s Washington, DC an

cago, Illinois, offices were used to mount a ‘‘public campaign

cure the Representative’s appointment to the U.S. Senate. In 

so, Representative Jackson may have violated federal la

House rules concerning the proper use of the Member’s Repr

tional Allowance. 

RECOMMENDATION: The Board of the Office of Congre

Ethics recommends that the Committee on Standards of 

Conduct review further the above allegations. 

VOTES IN THE AFFIRMATIVE: 6 

VOTES IN THE NEGATIVE: 0 

MEMBER OF THE BOARD OR STAFF DESIGNATE

PRESENT THIS REPORT TO THE COMMITTEE ON S

ARDS OF OFFICIAL CONDUCT: Leo Wise, Staff Director & 

Counsel. 


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TABLE OF CONTENTS 

I. INTRODUCTION .....................................................................................

A. Summary of Allegations .............................................................

C. Jurisdictional Statement ............................................................

D. Procedural History ......................................................................

E. Summary of Investigative Activity ............................................

II. SEEKING APPOINTMENT TO THE U.S. SENATE ............................

A. Applicable Laws, Rules and Standards of Conduct .................

B. A Sworn Statement Filed in United States District Court Co

tains Statements of Former Governor Blagojevich that an ‘‘E

issary’’ Acting on Behalf of Representative Jackson Offer

to Raise Money for Blagojevich in Exchange for Appointi

Representative Jackson to the Senate Seat ...........................

C. Representative Jackson Authorized Raghuveer Nayak to Ad

cate on His Behalf to Governor Blagojevich for Appointme

to the Senate .............................................................................

D. Representative Jackson Described Nayak as a ‘‘Prolific’’ a

‘‘Obsessive’’ Fundraiser for Blagojevich ..................................

E. On a Previous Occasion, Blagojevich Himself Told Represen

tive Jackson that he Considered Political Contributions 

Making Appointments ..............................................................

F. Representative Jackson was Told that Blagojevich Sought Som

thing of Value in Exchange for the Senate Appointment .....

III. THE MEMBER’S REPRESENTATIONAL ALLOWANCE ...................

A. Applicable Laws, Rules and Standards of Conduct .................

B. Use of House Resources in Pursuit of Appointment to the Unit

States Senate ............................................................................

IV. CONCLUSION ..........................................................................................

V. INFORMATION THE OCE WAS UNABLE TO OBTAIN AN

RECCOMMENDATIONS FOR THE ISSUANCE OF SUBPOENAS 


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1 As per Rule 9 of the OFFICE OF CONGRESSIONAL ETHICS, RULES FOR T

DUCT OF INVESTIGATIONS 11 (2009), ‘‘in the event the Office is unable to obtain in

necessary to reach that determination [that there is substantial reason to believe t

tions], but the Board does determine there is probable cause to believe the allega

Board may refer the matter to the Standards Committee for further review.’’ See a

895, 110th Cong. §1(c)(2)(B) (2008) (as amended). 

FINDINGS OF FACT AND CITATIONS TO LAW 

Review No. 09–9812 

On July 24, 2009, the Board of the Office of Congressional 

(hereafter ‘‘Board’’) adopted the following findings of fact a

companying citations to law, regulations, rules and stand

conduct (in italics). The Board notes that these findings do n

stitute a determination that a violation actually occurred. 

I. INTRODUCTION 

1. On December 9, 2008, Rod Blagojevich, the then Gove

the State of Illinois, was arrested on federal corruption c

for, among other conduct, allegedly attempting to ‘‘sell’’ the 

States Senate seat held by then President-elect Barack Ob

complaint unsealed on the day of the arrest contains stat

from Governor Blagojevich that an ‘‘emissary’’ from Represe

Jackson had offered to raise money for Blagojevich and 

‘‘money up-front,’’ if Blagojevich nominated Representative J

to the Illinois Senate seat being vacated by President Obama

2. In the course of conducting this review, the OCE learn

staff resources of the Representative’s Washington, DC an

cago, Illinois, offices were used to mount a ‘‘public campaign

cure the Representative’s appointment to the U.S. Senate. 

A. SUMMARY OF ALLEGATIONS

3. There is probable cause to believe that Representative J

either (1) directed a third-party, most likely Mr. Raghuveer 

to offer to raise money for Governor Blagojevich in exchange 

pointing Representative Jackson to the Senate seat, or (

knowledge that Nayak would likely make such an offer onc

resentative Jackson authorized him to advocate on his beha

Governor Blagojevich. Because former Governor Blagojevich, 

and Mr. Rajinder Bedi have declined to cooperate with the O

vestigation, and because the OCE cannot compel their coope

the OCE is unable to determine whether there is a substant

son to believe these allegations.1

4. There is substantial reason to believe that Represe

Jackson violated federal law and rules promulgated by th

mittee on House Administration concerning the proper use 

Member’s Representational Allowance. Specifically, the 

learned from Representative Jackson and his staff that s


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2 H. Res 895, 110th Cong. § 1(e) (2008) (as amended). 

3Some documents and interviews were requested by the OCE staff prior to June 

but were not provided to the OCE until after this date. 

sources both in the Representative’s Washington, DC and C

Illinois, offices were used to mount a ‘‘public campaign’’ to 

the Representative’s appointment to the Senate. 

B. JURISDICTIONAL STATEMENT

5. The allegations that were the subject of this review c

Representative Jesse Jackson, Jr., a Member of the United 

House of Representatives from the 2nd District of Illinois. T

olution the United States House of Representatives adopt

ating the Office of Congressional Ethics directs that, ‘‘[n]o 

shall be undertaken’’ . . . by the board of any alleged violati

occurred before the date of adoption of this resolution. 2 The 

adopted this Resolution on March 11, 2008. Because the c

under review occurred after March 11, 2008, review by the 

is in accordance with the Resolution. 

C. PROCEDURAL HISTORY

6. A preliminary review in this matter commenced on A

2009, following a written request by at least two members 

OCE Board made on March 26, 2009. 

7. At least three members of the Board voted to initiate a 

phase review in this matter on April 24, 2009. The second 

review commenced on May 1, 2009. 

8. The Board voted to extend the 45-day second-phase rev

an additional 14 days on June 12, 2009, as provided for un

Resolution. 

9. The second-phase review ended on June 30, 2009.3

10. The Board voted to refer the matter to the Commi

Standards of Official Conduct for further review and adopte

findings on July 24, 2009. 

11. This report and findings were transmitted to the Com

on Standards of Official Conduct on August 6, 2009. 

D. SUMMARY OF INVESTIGATIVE ACTIVITY

12. Over the course of its Review, the OCE interviewed: 

(1) Representative Jesse Jackson, Jr.; 

(2) Representative Jackson’s Chief of Staff; 

(3) Representative Jackson’s District Director; 

(4) Representative Jackson’s Scheduler; 

(5) Witness A, a Chicago businessman and former Presi

Federal of Indian Associations; and 

(6) Representative Jackson’s brother. 

13. In addition, the office requested and received doc

from: 

(1) Representative Jesse Jackson, Jr.; 

(2) Representative Jackson’s Chief of Staff; and 

(3) Representative Jackson’s Scheduler. 

14. The Office requested documents from and interviews w

following individuals who declined to cooperate in the OC

view: 


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4 COMM. ON STANDARDS OF OFFICIAL CONDUCT, 110TH CONG., HOUSE 

MANUAL 12 (2008). 5 COMM. ON STANDARDS OF OFFICIAL CONDUCT, REPORT UNDER THE AU

OF H. RES. 418, H. REP. NO. 1176, 90TH CONG., 2D SESS. 17 (1968). 

(1) Mr. Rod Blagojevich; 

(2) Mr. Raghuveer Nayak; and 

(3) Mr. Rajinder Bedi. 

II. SEEKING APPOINTMENT TO THE U.S. SENATE 

A. APPLICABLE LAWS, RULES AND STANDARDS OF CONDUC

15. 18 U.S.C. § 201(b)(1). Bribery of public officials and wi

(b) Whoever- 

(1) directly or indirectly, corruptly gives, offers or promis

thing of value to any public official or person who has been s

to be a public official, or offers or promises any public off

any person who has been selected to be a public official to gi

thing of value to any other person or entity, with intent— 

(A) to influence any official act; or 

(B) to influence such public official or person who has b

lected to be a public official to commit or aid in committ

collude in, or allow, any fraud, or make opportunity for the c

sion of any fraud, on the United States; or 

(C) to induce such public official or such person who has b

lected to be a public official to do or omit to do any act in vi

of the lawful duty of such official or person; 

shall be fined under this title or not more than three tim

monetary equivalent of the thing of value, whichever is grea

imprisoned for not more than fifteen years, or both, and may 

qualified from holding any office of honor, trust, or profit un

United States. 

16. 18 U.S.C. § 201(c). Illegal Gratuities 

(c) Whoever- 

(1) otherwise than as provided by law for the proper disch

official duty— 

(A) directly or indirectly gives, offers, or promises anyth

value to any public official, former public official, or person s

to be a public official, for or because of 

any official act performed or to be performed by such pub

cial, former public official, or person selected to be a public 

shall be fined under this title or imprisoned for not more th

years, or both. 

17. U.S. House of Representatives Code of Official Conduct 

Under House Rule 23, clause 1 (Code of Conduct), ‘‘[a] M

Delegate, Resident Commissioner, officer, or employee of the 

shall behave at all times in a manner that shall reflect cre

on the House.’’ This ethics standard is considered to be ‘‘th

comprehensive provision’’ of the code.4 When this section w

adopted, the Select Committee on Standards of Official Con

the 90th Congress noted that it was included within the C

deal with ‘‘flagrant’’ violations of the law that reflect on ‘‘C

as a whole,’’ and that might otherwise go unpunished.5 Th

has been relied on by the Ethics Committee in numerous prio

in which the Committee found unethical conduct including: t


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6 COMM. ON STANDARDS OF OFFICIAL CONDUCT, IN THE MATTER OF REPR

TIVE JOHN J. MCFALL, H. REP. NO. 95–1742, 95TH CONG., 2D SESS. 2–3 (197

1); IN THE MATTER OF REPRESENTATIVE EDWARD R. ROYBAL, H. REP. NO

95TH CONG., 2D SESS. 2–3 (1978). 7 COMM. ON STANDARDS OF OFFICIAL CONDUCT, IN THE MATTER OF REPR

TIVE CHARLES H. WILSON (OF CALIFORNIA), H. REP. NO. 95–1741, 95TH C

SESS. 4–5 (1978); H. REP. NO. 95–091743 (COUNTS 3–4). 8 COMM. ON STANDARDS OF OFFICIAL CONDUCT, IN THE MATTER OF REPR

TIVE MICHAEL J. MYERS, H. REP. NO. 96–1387, 96TH CONG., 2D SESS. 2, 5 (1

126 CONG. REC. 28953–78 (OCT. 2, 1980) (debate and vote of expulsion); IN THE 

OF REPRESENTATIVE JOHN W. JENRETTE, JR., H. REP. NO. 96–1537, 96TH C

SESS. 4 (1980) (Member resigned); IN THE MATTER OF REPRESENTATIVE RAY

LEDERER, H. REP. NO. 97–110, 97TH CONG., 1ST SESS. 4, 16–17 (1981) (Membe

after Committee recommended expulsion). In another case, the Committee issued a 

of Alleged Violation concerning bribery and perjury, but took no further action when 

ber resigned (IN THE MATTER OF REPRESENTATIVE DANIEL J. FLOOD, H. REP

856, 96TH CONG., 2D SESS. 4–16, 125–126 (1980)). 9 COMM. ON STANDARDS OF OFFICIAL CONDUCT, IN THE MATTER OF REPR

TIVE MARIO BIAGGI, H. REP. NO. 100–506, 100TH CONG., 2D SESS. 7, 9 (1988

resigned while expulsion resolution was pending). 10 COMM. ON STANDARDS OF OFFICIAL CONDUCT, IN THE MATTER OF REP

ATIVE CHARLES H. WILSON (OF CALIFORNIA), H. REP. NO. 96–930, 96TH C

SESS. 4–5 (1980); see 126 Cong. Rec. 13801–20 (June 10, 1980) (debate and vote o

11 Complaint, United States v. Blagojevich, Dec. 7, 2008 (N.D.Ill.)(Exhibit 1 at 

000074–000076). 12 Jonathan Weisman, Clare Ansberry and Douglas Belkin, Graft Case Touches Ja

WALL ST. J., Dec. 11, 2008 (Exhibit 2 at 09–9812–000081). 

ure to report campaign contributions,6 making false statem

the Committee,7 criminal convictions for bribery,8 accepting 

gratuities,9 and accepting gifts from persons with interest in 

tion in violation of the gift rule.10

B. A SWORN STATEMENT FILED IN UNITED STATES DISTRICT 

CONTAINS STATEMENTS OF FORMER GOVERNOR BLAGOJEVIC

AN ‘‘EMISSARY’’ ACTING ON BEHALF OF REPRESENTATIVE JA

OFFERED TO RAISE MONEY FOR BLAGOJEVICH IN EXCHANGE F

POINTING REPRESENTATIVE JACKSON TO THE SENATE SEAT

18. On December 7, 2008, the United States Attorney 

Northern District of Illinois submitted a sworn affidavit of 

W. Cain, a Special Agent with the Federal Bureau of Invest

in support of a criminal complaint against Rod R. Blagojevi

John Harris.11 Within that sworn statement is a transcrip

cordings of Blagojevich and various other individuals th

erences ‘‘Senate Candidate 5.’’ An attorney for Representativ

son has publicly stated that Representative Jackson is lik

person referred to as ‘‘Senate Candidate 5.’’ 12 The affidavit 

Cain states the following: 

115. Throughout the past month, ROD BLAGOJEVIC

continued to engage in numerous conversations relating 

ing the open Senate seat. In these conversations, he 

peatedly discussed the attributes of potential candida

cluding, among other things, the candidates’ ability to 

the State of Illinois, and the personal and political bene

himself and his family of appointing particular cand

These calls have included the following: 

a. On December 4, 2008, ROD BLAGOJEVICH spoke t

sor B and informed Advisor B that he was giving Sena

didate 5 greater consideration for the Senate seat b

among other reasons, if ROD BLAGOJEVICH ran for 

tion Senate Candidate 5 would ‘‘raise [ ] money’’ fo

BLAGOJEVICH, although ROD BLAGOJEVICH said he 


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‘‘get some (money) up front, maybe’’ from Senate Cand

to insure Senate Candidate 5 kept his promise about 

money for ROD BLAGOJEVICH. (In a recorded conve

on October 31, 2008, ROD BLAGOJEVICH described an 

approach by an associate of Senate Candidate Five as 

‘‘We were approached ‘‘pay to play.’’ That, you know, he

me 500 grand. An emissary came. Then the other guy 

raise a million, if I made him (Senate Candidate 5) a Sen

b. Later on December 4, 2008, ROD BLAGOJEVICH s

Fundraiser A. ROD BLAGOJEVICH stated he was ‘‘ele

Senate Candidate 5 on the list of candidates for the ope

ate seat. ROD BLAGOJEVICH stated he might be able 

a deal with Senate Candidate 5 that provided 

BLAGOJEVICH with something ‘‘tangible up front.

BLAGOJEVICH noted he was going to meet with Sena

didate 5 in the next few days. ROD BLAGOJEVICH told 

raiser A to reach out to Individual D, an individual wh

BLAGOJEVICH is attempting to obtain campaign co

tions from and who, based on intercepted phone calls

BLAGOJEVICH believes to be close to Senate Candi

ROD BLAGOJEVICH told Fundraiser A to tell Indivi

that Senate Candidate 5 was very much a realistic can

for the open Senate seat, but that ROD BLAGOJEVIC

getting ‘‘a lot of pressure’’ not to appoint Senate Candi

ROD BLAGOJEVICH told Fundraiser A to tell Indivi

that ROD BLAGOJEVICH had a problem with Senat

didate 5 just promising to help ROD BLAGOJEVICH b

ROD BLAGOJEVICH had a prior bad experience with 

Candidate 5 not keeping his word. ROD BLAGOJEVIC

Fundraiser A to tell Individual D that if Senate Cand

is going to be chosen to fill the Senate seat ‘‘some of thi

gotta start happening now . . . right now . . . and w

see it. You understand?’’ ROD BLAGOJEVICH told Fun

A that ‘‘you gotta be careful how you express that and 

everybody’s listening, the whole world is listening. Yo

me?’’ ROD BLAGOJEVICH told Fundraiser A to tell Ind

D if there is ‘‘tangible political support (campaign co

tions) like you’ve said, start showing us now.’’ Fundra

stated he will call Individual D on the phone to comm

ROD BLAGOJEVICH’s message. ROD BLAGOJEVIC

sponded that ‘‘I would do it in person. I would not do it 

phone.’’ ROD BLAGOJEVICH told Fundraiser A to c

nicate the ‘‘urgency’’ of the situation to Individual D. 


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13Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 (Ex

09–9812—000125). 14Plea Agreement, United States v. Harris (N.D. Ill) (Exhibit 4 at 09–9812—000099

15 Christopher Drew, Businessman Tied to Fund-Raising Offer to Blagojevich, N.Y

Dec. 15, 2008 (Exhibit 5 at 09–9812—000116). 

19. According to Representative Jackson, he met 

Blagojevich to discuss the Senate seat on December 8, 20

day before Blagojevich’s arrest on December 9, 2008.13

20. On July 8, 2009, John Harris, the other named defen

the above cited criminal complaint pled guilty to one count 

est services fraud in violation of 18 U.S.C. §§ 1343 and 134

plea agreement filed in the United States District Court 

Northern District of Illinois contains facts similar to the 

the Cain affidavit.14

21. The similarity between these facts and the facts in th

Affidavit suggest that Senate Candidate A is Representativ

son. 

C. REPRESENTATIVE JACKSON AUTHORIZED RAGHUVEER NAYAK 

VOCATE ON HIS BEHALF TO GOVERNOR BLAGOJEVICH FOR AP

MENT TO THE SENATE

22. Press accounts claim ‘‘investigators’’ subsequently ide

Raghuveer Nayak as an individual who offered to raise mo

Blagojevich on behalf of Representative Jackson.15 Press 

did not expressly state that investigators confirmed that 

was the ‘‘emissary’’ referred to by Blagojevich. Naya

Blagoveich have refused to cooperate with the OCE’s invest

Because the OCE cannot compel their testimony, the OCE 

able to confirm whether Nayak is the ‘‘emissary’’ to 

Blagojevich referred. 


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16Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 (Ex

09–9812—000122). 17 Id. at 09–9812—000120. 18 E-mail from Jesse Jackson to Kenneth Edmonds and Rick Bryant, Oct. 22, 200

12 at 09–9812—000235). 19Letter from Kenneth Edmonds to Raghu Nayak, Oct. 24, 2008 (Exhibit 13 at 

000237). 20Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 (Ex

09–9812—000121–000122). 

23. The OCE asked Representative Jackson whether he 

ized Nayak to advocate on his behalf for appointment to the 

with Blagojevich. Representative Jackson told the OCE he 

assistance from ‘‘anyone and everyone’’ including Nayak.16

24. According to Representative Jackson, the first time he 

with Mr. Nayak regarding the Senate seat was at the Dem

National Convention in 2008. According to Representative J

the conversations were not substantive and consisted mainly 

Nayak calling Representative Jackson ‘‘Senator.’’ 17

25. On October 22, 2008, Representative Jackson sent an 

to members of his staff about preparing a letter for Nayak 

culate among the Indian-American community in support 

resentative Jackson for the Obama Senate seat.18

26. On October 24, 2008, Representative Jackson’s Chief 

sent the letter to Mr. Nayak via email.19

27. Representative Jackson told the OCE that after the 

cratic National Convention, the next time he and Mr. Nayak 

in person about the Senate appointment was on October 28

during a meeting at a local Chicago restaurant. Represe

Jackson provided OCE with the following facts about that 

ing: 20

a. Mr. Nayak, Mr. Rajinder Bedi (an economic developm

ficial in Illinois state government assigned to the Secon

gressional District), District Director and Representativ

son were in attendance. Mr. Nayak had arranged the m

Governor Blagojevich spontaneously assigned Mr. Bed

the Second District’s liaison for economic developme

years prior at an Indian Day parade. The October 28th 

ing represented Mr. Bedi’s first follow up since that da

resentative Jackson did not know Mr. Bedi well, but, i

tion to his role as liaison, he knew him to be a friend 

Nayak and someone who would attend various fund

events in the company of Mr. Nayak. According to Repr

tive Jackson, the meeting was held to discuss the possib

constructing an airport in the Second Congressional D

However, Mr. Nayak had no role in the district’s econo

velopment and no role in the airport’s development. 

b. Representative Jackson recalled that the meeting las

approximately 45 minutes to one hour. Mr. Nayak arriv

Upon Mr. Nayak’s arrival, he stated to Representative J

words to the effect of, ‘‘you are going to be the Senator

‘‘we want you to be the Senator.’’ Representative Jacks

tinctly recalled his response as, ‘‘that would be a two-f

ferring to both the airport and becoming Senator. Repr

tive Jackson then continued to speak about the airport. 

c. After the meeting, Mr. Bedi and Mr. Nayak went to th

door and had another conversation that Representativ


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21Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 (Ex

09–9812—000122). 22Memorandum of Interview of the District Director for Representative Jackson, Ap

(Exhibit 7 at 09–9812—000130). 23Memorandum of Interview of the Chief of Staff of Representative Jackson, Apr

(Exhibit 8 at 09–9812—000142). 24Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 (Ex

09–9812—000125). 25 Id. 26 Id. 

son could not hear. Representative Jackson and District 

tor stayed at the table to discuss an upcoming meeting. 

28. Although he initially recalled the conversation about th

ate seat lasting for about 10 minutes, Representative Jackso

revised his recollection and stated that this exchange was t

reference made to the Senate seat during the October 28th 

ing.21

29. The District Director for Representative Jackson a

tended the October 28, 2008 meeting and described it in an 

view with the OCE as follows:22

a. On October 28, 2008 the Representative met with Mr. 

and Mr. Rajinder Bedi at a restaurant called ‘‘312’’ acro

street from a state office building. District Director attend

meeting. Mr. Bedi came to the meeting with Mr. Nayak. Mr. 

did not have anything to do with the airport project. When 

why he was there, the District Director said he thought Mr. 

was there to introduce Mr. Bedi to the Representative sin

Nayak and Mr. Bedi were friends. District Director does 

member any of the conversation about the Senate seat. Dist

rector also said that at some point, Mr. Nayak and Mr. Bed

talking to one another (they were seated side-by-side acr

table from District Director and the Representative). District 

tor said he could not hear their entire conversation but d

them talk about ‘‘fundraising.’’ 

30. Representative Jackson’s Chief of Staff had no knowl

this meeting when the OCE interviewed him.23

31. According to Representative Jackson, after Go

Blagojevich was arrested, he and his father, Reverend Jess

son, Sr. talked on the phone about the possible identities of i

uals listed in the criminal complaint who were identified by 

betical letters.24 Reverend Jesse Jackson, Sr. suggested that 

them might be Mr. Rajhuveer Nayak. Reverend Jackson pla

son on hold, called Mr. Nayak, and conferenced him into t

versation with his son. Representative Jackson asked Mr. N

one of the individuals in the complaint and Mr. Nayak said 

not.25

32. According to Representative Jackson, Mr. Nayak nev

him that he was arranging to raise money for the Senate se

did it ever come to the Member’s attention—directly or indir

that Mr. Nayak might be doing so. The last time Represe

Jackson spoke with Mr. Nayak was either the day of or t

after the arrest of Governor Blagojevich.26


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27Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 (Ex

09–9812—000122). 28Memorandum of Interview of the Chief of Staff of Representative Jackson, Apr

(Exhibit 7 at 09–9812—000141). 29Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 (Ex

09–9812—000125). 30 Id. 31Memorandum RE: Rep. Jesse L. Jackson, Jr.’s Potential Appointment to the U.

Dec. 8, 2008 (Exhibit 16 at 09–9812—000246). See also Memorandum of Interview of R

ative Jesse Jackson, Jr., Apr. 9, 2009 (Exhibit 6 at 09–9812—000125). 32Transcript of Proceedings had at the interview of Witness A, Jun. 17, 2009 (Exh

09–9812—000211). 33 Id. at 09–9812—000214. 34 Id. at 09–9812—000204. 

D. REPRESENTATIVE JACKSON DESCRIBED NAYAK AS A ‘‘PROLIFI

‘‘OBSESSIVE’’ FUNDRAISER FOR BLAGOJEVICH

33. Representative Jackson described Mr. Nayak as both 

lific’’ and ‘‘obsessive’’ supporter and fundraiser for Rod Blag

and as Rod Blagojevich’s ‘‘guy.’’ 27

34. Representative Jackson’s Chief of Staff told the OCE 

did not know the exact nature of Mr. Nayak’s relationshi

Rod Blagojevich, but he had the impression Mr. Nayak was 

lific’’ fundraiser for the Democratic Party—raising mon

Barack Obama, Hillary Clinton, Joseph Biden, an

Blagojevich.28

35. Representative Jackson told the OCE he did not s

Nayak as an ‘‘operative’’ for assisting his campaign for the 

seat. Nevertheless, Representative Jackson told the OCE he 

assistance from anyone and everyone, including Mr. Nayak. 

not give Mr. Nayak any explicit directions on how to ass

campaign for the seat, nor did he place any explicit restrict

Mr. Nayak’s assistance.29

36. Overall, the only restrictions or caveats Representativ

son placed on those who promoted his campaign for the Sena

were contained in notes attached to an informational pack

gave some of his supporters.30 Those notes explained the 

of the Illinois political landscape and included the fact th

Governor was under investigation for ‘‘pay to play’’ politics.31

37. Witness A, a Chicago-area businessman and past pr

of Federation of Indian Associations told the OCE that he at

an event on October 31, 2008, at the India House Restau

Shaumburg, Illinois, three days after Representative Ja

meeting with Bedi and Nayak. Witness A told the OCE h

heard a conversation between Nayak, Bedi and a third ind

and that he specifically heard these three persons dis

‘‘tell[ing] Babu Patel to tell Governor [Blagojevich] to appoin

Jackson, Jr. as a senator.’’ 32 When Witness A overheard t

versation, Witness A was speaking with Mr. Patel. Witness 

told the OCE that Mr. Patel had previously held severa

raisers for Governor Blagojevich and had invited him to th

ber 31, 2008 luncheon.33

38. Witness A also told the OCE that Governor Blagojevic

a speech at the October 31, 2008 luncheon.34 According to W

A, after the Governor spoke, Bedi told the group that the

going to be a fundraiser for Governor Blagojevich to celebr


bjneal on DSK2TWX8P1PROD with HEARING
35 Id. at 09–9812—000205. 36 Id. at 09–9812—000209. 37Memorandum of Interview of Family Member A, Jun. 4, 2009 (Exhibit 11 at 

000233); Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 200

6 at 09–9812—000124). 38Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 (Ex

09–9812—000124). 39 Id. 40 Id. 41 Id. at 09–9812—000123. See also, Memorandum of Interview of the District D

Representative Jackson, Apr. 9, 2009 (Exhibit 7 at 09–9812—000129). 

dian New Year, Diwali, and the group was asked to buy ta

this event.35

39. According to Witness A, the Indian New Year fundra

curred on December 6, 2008. He attended and wrote a $1,00

for Governor Blagojevich’s re-election campaign.36

40. Representative Jackson’s brother also attended that 

Representative Jackson’s brother and Representative Jackso

told the OCE that it was not a fundraiser for Blagojevich.37

E. ON A PREVIOUS OCCASION, BLAGOJEVICH HIMSELF TOL

RESENTATIVE JACKSON THAT HE CONSIDERED POLITICAL CON

TIONS IN MAKING APPOINTMENTS

41. Representative Jackson told the OCE that on a previou

sion Governor Blagojevich had told him he considered politic

tributions when making appointments.38

42. Representative Jackson told the OCE that in 2002 

asked by former Representative Bill Lipinski to donate $25

the campaign of then-Representative Rod Blagojevich for Go

of Illinois. Representative Jackson declined to do so. After h

tion, the new Governor asked Representative Jackson if the

anything he could do for the Representative. Representativ

son asked the Governor to consider his wife for a job. Repr

tive Jackson was told to submit information on his wife t

Rezko and that she would be considered for the position of 

Commissioner. Ultimately, Ms. Jackson was not chosen for 

net position.39

43. Subsequently, on the floor of the U.S. House, Represe

Jackson talked with former Representative, then Go

Blagojevich. Representative Jackson told him ‘‘no hard fe

and Governor Blagojevich agreed but added, ‘‘you shoul

given me that $25,000.’’ 40

F. REPRESENTATIVE JACKSON WAS TOLD THAT BLAGOJEVICH S

SOMETHING OF VALUE IN EXCHANGE FOR THE SENATE APPOIN

44. According to Representative Jackson and the District 

tor, on two occasions Representative Jackson was told tha

ernor Blagojevich was looking for something of value in ex

for the Senate appointment.41

45. According to Representative Jackson, he received a tex

sage from Mr. Mark O’Malley on November 11, 2008, offer

support. Representative Jackson responded by saying th

O’Malley could help by putting the Representative in touc

anyone who knows the Governor. Mr. O’Malley promptly 

Representative Jackson to his restaurant that same day for 


bjneal on DSK2TWX8P1PROD with HEARING
42Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 (Ex

09–9812—000123). 43Memorandum of Interview of the District Director for Representative Jackson, Ap

(Exhibit 7 at 09–9812—000129). 44 Id. 45Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 (Ex

09–9812—000123). 

ing with Mr. Mark Rumman, a former high-ranking official 

Blagojevich administration.42

46. Representative Jackson’s District Director confirmed th

O’Malley contacted Representative Jackson and offered t

with the Senate selection process. The District Director t

OCE that Mr. O’Malley helped arrange a meeting between th

resentative and Mr. Rumman. The District Director provid

following facts about that meeting: 43

a. At that meeting, Mr. Rumman told Representative J

he had heard that the Governor was ‘‘completely und

about the Senate seat. 

b. The Governor’s inner circle described him as ‘‘delu

and said he was ‘‘not in touch with reality’’ in terms of h

political future. Blagojevich’s ‘‘inner circle’’ told him hi

ical life was over and that he should ‘‘keep his nose clea

finish out his term. 

c. Nonetheless, Governor Blagojevich talked about runn

reelection. 

d. When the Governor was ‘‘in his saner moments’’ he 

about his daughters and his family and is intereste

‘‘high-paying job’’ after politics. 

e. Mr. Rumman told Representative Jackson that Blag

was looking for a ‘‘lifeline.’’ The Representative ask

Rumman what that term meant. Mr. Rumman explain

Blagojevich will be looking for a high-paying job and ex

that was why J.B. Pritzker was under consideration 

Senate seat—because Pritzker was in a good position 

him one. The Representative said that is precisely the 

thing that got him in trouble in the first place’’—some 

tradeoff. 

f. Mr. Rumman volunteered to attempt to collect more in

tion on the Governor’s deliberations and report back 

Representative. 

47. According to District Director, Mr. Rumman, Mr. O’

District Director and the Representative met the next mor

a restaurant called ‘‘Yolk’’ for approximately 30 minute

Rumman reported he had made some calls the previous e

but had no new information.44

48. According to Representative Jackson, he met with M

Wyma, an advisor and confidant of Rod Blagojevich, in th

part of December 2008. Representative Jackson provided t

lowing facts to the OCE about that meeting: 45

a. During the meeting Representative Jackson relayed 

Wyma that he wanted the seat and wanted a meeting w

Governor. Mr. Wyma asked about Representative Jacks

lationship with the Governor and Representative Jack

plied that it was ‘‘frosty.’’ Mr. Wyma’s response was 

Representative Jackson wanted a meeting with Go


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46Memorandum of Interview of the District Director for Representative Jackson, Ap

(Exhibit 7 at 09–9812—000132). 47David Kidwell, Blagojevich fundraiser held by Jackson allies Saturday, CHI TRIB

2008 (Exhibit 3 at 09–9812—000087). 48Memorandum of Interview of the District Director for Representative Jackson, Ap

(Exhibit 7 at 09–9812—000131). 49Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 (Ex

09–9812—000125). 

Blagojevich then ‘‘trust needed to be built.’’ Mr. Wyma 

that Representative Jackson’s best argument for bei

pointed was that as Senator he could support the Gove

his 2010 campaign for reelection. Mr. Wyma then aske

resentative Jackson if he would support the Governor in 

As the meeting ended, Representative Jackson ask

Wyma for anything he could do to help him get a meetin

the Governor. 

b. While Representative Jackson was taking a phone ca

Wyma wrote a note and handed it to Representative J

On the note were several bullet points: Building trust a

sonal relationship; Historical significance/Importance 

seat; and the case for your candidacy/lifeline. 

c. This note was not turned over to any federal or state 

gator. Representative Jackson’s attorney stated duri

interview that he has the note, but it was misplaced. 

d. According to Representative Jackson, the subject o

raising did not come up during the meeting with Mr. 

49. Representative Jackson’s District Director accompanie

resentative Jackson to the Representative’s meeting 

Blagojevich on December 8, 2008, but did not go in the roo

the Governor and Representative. The District Director s

meeting began at 5:00 pm and lasted 90 to 120 minutes. T

trict Director said the Representative told him when he ca

that he was ‘‘as confused coming out as he was when he w

about his prospects. The District Director asked the Represe

if ‘‘anything like a quid pro quo’’ came up because, the Dist

rector said he told the Representative, ‘‘this guy is notori

that’’ The Representative told him ‘‘no’’ and said they went t

the notebook that Jackson had brought with him on why he 

be selected.46

50. A December 12, 2008 Chicago Tribune article quoted t

trict Director, as saying, ‘‘He [the Representative] has ta

[Nayak] about the Senate seat and he has mentioned his i

. . . But he never asked him to do anything.’’ 47

51. In his interview with OCE, the District Director at fir

he did not remember making that statement and that he 

know the basis for his statement. Later in the interview he 

remembered getting a call from a reporter at his home arou

pm on December 11, 2008 and being asked whether the Rep

ative had talked to Nayak about the Senate seat. The Dist

rector said he had called the Representative and that he ha

him this statement and that the District Director only ‘‘c

the ‘‘I’’ to ‘‘he.’’ 48

52. Representative Jackson told the OCE that he did not g

District Director any statement for this December 12, 200

cle.49


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50 COMM. ON HOUSE ADMIN., MEMBERS’ CONGRESSIONAL HANDBOOK at 6

51 Id. at 6–7. 52 COMM. ON STANDARDS OF OFFICIAL CONDUCT, 110TH CONG., HOUSE 

MANUAL 123 (2008). 53 Id. at 124. 54 Id. at 126 (referring to 18 U.S.C. § 1001 and 31 U.S.C. §§ 3729–3731, commonl

to as the False Claims Act). 55 Id.1 at 132. 56 Id. at 133. 57 Id. 58 Id. 59 Id. at 135. 60 Id. 61 Id. at 324. 

III. THE MEMBER’S REPRESENTATIONAL ALLOWAN

A. APPLICABLE LAWS, RULES AND STANDARDS OF CONDUC

53. 31 U.S.C. § 1301(a). Appropriations 

‘‘Appropriations shall be applied only to the objects for wh

appropriations were made except as otherwise provided by la

54. U.S. House of Representatives Committee on House A

tration, Members Handbook 

‘‘[O]nly expenses the primary purpose of which are offici

representational and which are incurred in accordance w

Handbook are reimbursable.’’ 50

‘‘The MRA may not pay for personal expenses’ The MRA m

pay for campaign expenses . . . The MRA may not pay for p

expenses.’’ 51

55. U.S. House of Representatives Ethics Manual 

‘‘[O]fficial resources of the House must, as a general rule, 

for the performance of official business of the House, and 

those resources may not be used for campaign or politic

poses.’’ 52 ‘‘Members and staff should be aware that the gener

hibition against campaign or political use of official resour

plies not only to any Member campaign for re-election, but 

to any campaign or political undertaking. Thus, the prohibit

plies to, for example, campaigns for the Presidency, the U.S. 

or a state or local office. . . .’’ 53

‘‘Members must regularly certify that all official funds ha

properly spent. A false certification may bring criminal pe

and the government may recover any amount improperly paid

The House Ethics Manual states that ‘‘limited campaign-

activities’’ may take place in a Congressional office, but limi

activities to (1) ‘‘coordination of the Member’s schedule,’’ 55 

secretary’s occasional response to questions on political ma

‘‘campaign/congressional office referrals,57 ‘‘providing pu

materials to the campaign,’’ 58 ‘‘responding to questionnaires 

islative issues,’’ 59 and ‘‘nonpartisan voter registration mater

‘‘A member is responsible for assuring that resources provi

support of official duties are applied to the proper purposes.’’ 

B. USE OF HOUSE RESOURCES IN PURSUIT OF APPOINTMENT T

UNITED STATES SENATE

56. Representative Jackson described mounting a ‘‘publi

paign’’ for appointment to the Senate. Specifically, his ‘‘cam

for the Senate seat was handled by his two senior-most staf


bjneal on DSK2TWX8P1PROD with HEARING
62 Memorandum of Interview of Representative Jesse Jackson, Jr., Apr. 9, 2009 

at 09–9812—000121). 63 Memorandum of Interview of the Chief of Staff of Representative Jackson, Apr

(Exhibit 7 at 09–9812—000142). 64 Memorandum of Interview of the District Director for Representative Jackson, Ap

(Exhibit 7 at 09–9812—000128). 65 Id. at 09–9812—000128. 66 Id. at 09–9812—000128. 67Memorandum of Interview of the District Director for Representative Jackson, Ap

(Exhibit 7 at 09–9812—000128). 68Memorandum of Interview of the Chief of Staff of Representative Jackson, Apr

(Exhibit 7 at 09–9812—000142). 

bers, his Chief of Staff and Press Secretary and his District 

tor using House resources.62

57. The Chief of Staff told the OCE that he did not rem

the first time Representative Jackson and he had a substant

cussion regarding the Senate seat. However, he said there 

awareness of the possibility of gaining an appointment to th

ate as early as the Democratic National Convention in 

2008. Chief of Staff recalled thinking the convention was im

and, as the date of the convention approached, began advisin

resentative Jackson to ‘‘conform his persona to one evocati

Senator.’’ 63

58. The District Director told the OCE that the idea o

resentative Jackson filling President Obama’s Senate sea

came up a year before the election.64

59. The District Director told the OCE that the Represe

concluded that the only way to be selected was to run a 

campaign.’’ This strategy was chosen because the Represe

had ‘‘no relationship’’ with the Governor and therefore th

resentative believed he needed a great deal of public sup

order to be a viable candidate.65

60. That campaign seems to have begun in fall 2008 w

looked like Senator Obama would win the presidency. The D

Director attended the press conference where Governor Blag

spoke about how he would select a replacement to fill the 

District Director also stated that a ‘‘plan was put into action

resentative Jackson wrote out a ‘‘case’’ for why he was quali

the Senate. The Representative, the District Director, a

Chief of Staff then contacted editorial boards in hopes of 

endorsements. When individual citizens would ask how the

help, they would be told to contact the Governor and advoc

Representative Jackson’s selection.67

61. The Chief of Staff described Representative Jackson 

natively as both the coach and quarterback of their campa

the seat or as the coach and himself as the quarterback. Th

out the public campaign, the Chief of Staff was involved in 

ings about the Senate seat and Representative Jackson ty

told the Chief of Staff when the Representative spoke to i

uals about the seat. However, according to the Chief of Sta

resentative Jackson was furiously pitching to numerous indi

for support and the Chief of Staff was not aware of every co

tion, but he thought he was aware of the significant ones.68

62. District Director stated that he would occasionally vo

for Representative Jackson’s campaign committee, but ne

scribed his action with regard to the Senate appointment as 

teer work associated with Representative Jackson’s campaign


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63. When asked about his position in the Jackson office, C

Staff only stated that he was Chief of Staff and did not d

any role with the campaign. 

64. The Board notes that when detailing how they went ab

curing the appointment to the Senate seat, both District D

and Chief of Staff described their roles in terms of their 

District Director and Chief of Staff, respectively. 


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69 Email from Representative Jackson to Kenneth Edmonds, Oct. 22, 2008 (Exhibit 

9812—000235). 70 Email from Kenneth Edmonds to Raghu Nayak, Oct. 22, 2008 (Exhibit 13 at 

000237). 71 Id. at 09–9812—000238. 

65. In emails provided to the OCE by Chief of Staff, it a

that the resources of Representative Jackson’s Congressiona

were used in the campaign for the seat. Specifically, Represe

Jackson sent the Chief of Staff and District Director an ema

his Blackberry on October 22, 2008, at 8:59 a.m. about pre

a letter for Mr. Nayak to circulate among the Indian-Am

community of Illinois for signatures in support of the Repr

tive’s bid for the Senate seat.69

66. Based on the format of the email, it appears it was 

Mr. Edmond’s Microsoft Outlook office account. On Octob

2008 at 11:34 a.m., the Chief of Staff sent the letter to Mr. 

via email.70 The email appears to have been sent from M

mond’s Congressional office account. Furthermore, his C

sional office signature block, describing him as the ‘‘Chief o

Office of Representative Jesse L. Jackson, Jr.’’ appears at t

of the email.71


bjneal on DSK2TWX8P1PROD with HEARING
72Timeline of Events (Exhibit 16 at 09–9812—000242). 73 Email from Rick Bryant to Rick Bryant, Nov. 12, 2008 (Exhibit 14 at 09–9812

74Memorandum of Interview of the Chief of Staff of Representative Jackson, Apr

(Exhibit 7 at 09–9812—000139). 

67. On November 9, 2008, after Barack Obama was elected 

dent, Representative Jackson sent an email to staff member

ing a meeting with former Illinois Governor Rod Blagojevich

68. On November 12, 2008 at 12:09 p.m., the District D

sent an article referencing Representative Jackson’s polling 

himself on what appears to be his District office email acc

69. The Chief of Staff told the OCE that around Novem

2008, he grew increasingly concerned about Representativ

son’s prospects for the appointment. In an attempt to gain 

ligence regarding the process, Representative Jackson reach

to an aide, Mr. Victor Roberson, and an unofficial advisor 

Governor, Mr. Michael Rumman. Mr. Rumman called the C

Staff back a few days later to apologize and say that he att

to find information but was unable to do so. Mr. Roberson 

provide any helpful information either.74


bjneal on DSK2TWX8P1PROD with HEARING
75Timeline of Events (Exhibit 16). 

70. The Chief of Staff provided the OCE with a timeline 

events and activities that he, District Director and the Repr

tive engaged in their ‘‘campaign’’ to secure the Representativ

pointment to the Senate.75


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76Memorandum RE: Rep. Jesse L. Jackson, Jr.’s Potential Appointment to the U.

Dec. 8, 2008 (Exhibit 9). 

71. According to Representative Jackson and material

resentative Jackson provided to the OCE, when the Represe

met with Governor Blagojevich on December 8, 2008 he p

the Governor with a copy of materials supporting his appoin

These materials contain the copies of the editorial endorsem

sought and received, endorsements from local elected offi

‘‘political memo,’’ and other materials that reflect the wor

resentative Jackson and his staff undertook on his behalf t

a case for his appointment to the Senate.76

72. In each of these instances, there is no evidence to 

District Director, Chief of Staff or any other staff member u

sources other than those of Representative Jackson’s Congre

or District offices. 

IV. CONCLUSION 

73. For the above reasons, the Board recommends that th

mittee on Standards of Official Conduct review further the 

allegations concerning Representative Jackson’s efforts in 


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appointment to the U.S. Senate and use of the Member’s Re

tational Allowance. 

V. INFORMATION THE OCE WAS UNABLE TO OBTAIN 

RECCOMMENDATIONS FOR THE ISSUANCE OF SUBPO

74. The Office requested documents from and interviews w

following individuals who declined to cooperate in the OC

view: 

(1) Mr. Rod Blagojevich; 

(2) Mr. Raghuveer Nayak; and 

(3) Mr. Rajinder Bedi. 

75. The OCE recommends the issuance of subpoenas to th

dividuals. 


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