Case: 1:20-cr-00368 Document 1 Filed: 07/17/20 Page 1 of 3 PageID #:91 

FILED

UNITED STATES DISTRICT COURT JUL 1 7 2020 AC
NORTHERN DISTRICT OF ILLINOIS THOMAS BRUTON
EASTERN DIVISION CLERK. u.s. DISTRICT COURT

UNITED STATES OF AMERICA 1 :20-cr?00368

Judge Judge John F. Kness
Magistrate M. David Weisman

COMMONWEALTH EDISON



V. 
3
COMPANY 

THE UNITED STATES ATTORNEY charges:
1. At times material to this information:

a. Defendant COMMONWEALTH EDISON COMPANY
(hereinafter, ?ComEd?), with headquarters located in Chicago, Was the
largest utility company in Illinois. As a utility, ComEd was subject to
extensive regulation by the State of Illinois.

b. The legislative branch of government for the State of
Illinois was commonly known as the Illinois General Assembly. The Illinois
General Assembly was composed of two houses: The House of
Representatives and the Senate. The Illinois General Assembly routinely
considered bills and passed legislation that had a substantial impact on
ComEd?s operations and pro?tability, including legislation that affected the

regulatory process used to determine the rates ComEd could charge

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customers for the delivery of electricity. ComEd maintained a continuing
interest in advancing legislation in the Illinois General Assembly favorable
to its interests, and opposing legislation that was not consistent with its
operational and financial success.

c. Public Official A was the Speaker of the House of
Representatives and an elected member of that body. As Speaker of the
House of Representatives, Public Official A was able to exercise control over
what measures were called for a vote in the House of Representatives.
Public Official A also exercised substantial influence and control over fellow
lawmakers concerning legislation, including legislation affecting ComEd.

2. Beginning no later than in or around 2011, and continuing
through in or around 2019, in the Northern District of Illinois, Eastern
Division, and elsewhere,

COMMONWEALTH EDISON COMPANY,
defendant herein, corruptly gave, offered, and agreed to give things of value,
namely, jobs, vendor subcontracts, and monetary payments associated with
those jobs and subcontracts, for the benefit of Public Official A and Public
Official A?s associates, with intent to in?uence and reward Public Official A,

as an agent of the State of Illinois, a State government that during each of

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the twelve?month calendar years from 2011 to 2019, received federal bene?ts
in excess of $10,000, in connection with any business, transaction, and series
of transactions of $5,000 or more of the State of Illinois, namely, legislation
affecting ComEd and its business;

In violation of Title 18, United States Code, Section 666(a)(2).



UWED STMES ATTORNEY