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Monday, August 20, 2007


MARCH 29, 2007

Christopher Christie
United States Attorney, District of New Jersey
970 Broad Street, 7th Floor
Newark, NJ 07102
Fax: 973-645-2702

Dear U.S. Attorney Christie:

We hereby request that you open a criminal investigation into the issue of Governor Corzine’s falsification of his United States Senate disclosure documents for the years 2002, 2003 and 2004. Just days ago the Governor admitted that he had amended his reports for those years to comply with Senate reporting requirements.

As you know, the United States criminal code specifically prescribes penalties for such records falsification.

The False Statements Accountability Act of 1996 (FSAA), Pub. L. No. 104-292, H.R. 3166 (October 11, 1996), made it clear that the Justice Department could investigate false statements made to the legislative branch. Indeed, 18 U.S.C. 1001 sets out criminal penalties for the falsification of documents such as the Senate Disclosure Reports.

There is abundant evidence that Governor Corzine knowingly and willfully falsified is Senate Disclosure Reports.

First, by extending a mortgage to Carla Katz using a Delaware corporation – JSC LLC – he appeared to be consciously hiding the mortgage and his relationship with Ms. Katz.

Second, Governor Corzine disclosed loans to other invididuals, indicating that he knew how to make the disclosures, but wanted to hide the transaction involving Carla Katz. In his 2000 Report Senator Corzine listed as an asset “Avis Yates – Personal Loan; Newark, NJ.” See Exhibit B, Part IIIB at p. 2 of 4. That same year, Senator Corzine listed as an asset “Two Skirts, LLC – loan to clothing store; Telluride, CO.” Id. In his 2001 Report, he listed as an asset “Diane Kessenich – New York, NY; Personal Loan.” See Exhibit C, Part IIIB at p. 2 of 5. There is no difference between the loans the Senator was obligated to report in 2000 and 2001 and that which he failed to disclose in 2002, 2003 and 2004. Thus, the only logical conclusion is that the Senator willfully chose not to disclose his interest in JSC INVESTMENTS, LLC in 2000, 2001 and 2002 and thereafter, willfully chose not to disclose JSC INVESTMENTS, LLC’s $470,000 asset, i.e., its mortgage interest in the home of Carla Katz.

Third, Governor Corzine appeared to try to cover up these loans. A reasonable person in Corzine’s position should have recognized that a Senator’s mortgage loan and subsequent forgiveness of a nearly one-half million dollar loan to a high union official is a matter of intense public interest that must be reported. Corzine and Katz have displayed an unreal and irresponsible attitude as to this gift, with Corzine saying it is a mere “personal” matter and Katz likening it to “box of chocolates”. See New York Times, August 4, 2005.
Since revelations of the mortgage were disclosed by media outlets, Governor Senator Corzine appears to have engaged in a cover-up. Then Senator Corzine first insisted on Friday, August 5, 2005 that he had disclosed the loan on his Report. See Asbury Park Pres., August 6, 2005.

Later that same Friday, Senator Corzine’s counsel Mark Elias said that the Senator had misspoken and the loan had not been disclosed but that it did not have to be disclosed because it was a personal transaction. Id.
Subsequently, the Senator, through spokesman, has maintained that mortgage is neither an asset nor an interest in real estate – two utterly fanciful assertions. Even more incredibly, the Senator has maintained that he did not have to report the interest because he later forgave it. This would mean that no Senator would have to report any interest, including in public companies, if they later forgave it.


Bruce Afran, Esq.
Hon. Carl J. Mayer, Esq.