placed on the bar. Instead, donations to the campaign had been taken by check at the fundraiser. f. Dickert instructed that the $1,000 given to Williams by Nicholson was to be reported as a campaign contribution from various individuals, including Nicholson, Nicholson’s wife, Williams, and other unknown individuals. g. Soon after the special April 2009 primary election, Dickert again instructed Williams to go to Ivanhoe’s pub, owned by Nicholson, to pick up money for Dickert. Upon arrival, Nicholson brought Williams into his office. Nicholson removed $1,000 in U.S. currency from his safe in the office. Nicholson told Williams that the money was from a fundraiser for Dickert’s campaign. h. Dickert instructed that the additional $1,000 given to Williams by Nicholson was to be reported as a campaign contribution of various unknown amounts from various unknown individuals. i. These bribes in April and May 2009 from Nicholson, LeGath, the Tavern League, and as-yet unidentified white bar owners were made with a criminal intent and were intended to influence Dickert’s appointments to the Licensing Committee and to ensure that minority-owned taverns were targeted by the City while Nicholson, LeGath, the Tavern League, and as-yet unidentified white bar owners would not have their businesses’ interrupted. j. Soon after the special April 2009 primary election, Dickert met with a known Racine business owner (“Business Owner”) to entice him to “do the same thing” that Nicholson had done. At the time of the election and shortly thereafter,
65 Case 2:14-cv-00208-JPS Filed 08/21/14 Page 65 of 119 Document 62