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Cisneros Indictment: Part Two

From the complete, unedited text of Independent Counsel David M. Barrett's Dec. 11, 1997, indictment against former housing secretary Henry G. Cisneros and three co-defendants.

Note: Typographical errors from the original document are preserved. Others may have been introduced by the scanning process.

Cisneros's Extramarital Affair With Medlar¹

[¹ Medlar currently goes by the name "Linda D. Jones." For purposes of clarity and consistency, she is referred to herein as "Linda Medlar," her name at the time of most events set forth herein.]

1. While residing in San Antonio, Texas, MEDLAR began working as a fundraiser for CISNEROS. At the time, CISNEROS was serving as Mayor of San Antonio, Texas. CISNEROS served as Mayor of San Antonio from in or about May 1981 until in or about May 1989.

2. In or about March 1987, while the pair were in New York for a fundraising event, CISNEROS and MEDLAR, both of whom were married to others, became involved in an extramarital affair. In or about October 1988, media reports were issued about the affair between MEDLAR and CISNEROS. From in or about October 1988 through in or about the Fall of 1989, MEDLAR and CISNEROS periodically lived together in San Antonio, Texas.

Cisneros's Payments To Medlar

Beginning in or about 1989 and continuing through in or about January 1994, CISNEROS made payments to MEDLAR. The total amount of such payments exceeded a quarter of a million dollars. The payments were made by cash, wire transfer, and direct deposits into MEDLAR's bank accounts.

1. CISNEROS made the following payments, among others, to MEDLAR, which were in the approximate amounts of $2,500 or more.

A. Payments To Medlar Before Cisneros's Tenure As HUD Secretary 1990 Payments

1. On or about January 2, 1990, CISNEROS made a payment to MEDLAR in the amount of $2,500.

2. On or about February 1, 1990, CISNEROS made a payment to MEDLAR in the amount of $3,000.

3. On or about March 5, 1990, CISNEROS made a payment to MEDLAR in the amount of $2,500.

4. On or about April 10, 1990, CISNEROS made a payment to MEDLAR in the amount of $2,500.

5. On or about May 3, 1990, CISNEROS made a payment to MEDLAR in the amount of $2,500.

6. On or about May 31, 1990, CISNEROS made a payment to MEDLAR in the amount of $4,500.

7. On or about June 29, 1990, CISNEROS made a payment to MEDLAR in the amount of $3,000.

8. On or about September 13, 1990, CISNEROS made a payment to MEDLAR in the amount of $3,900.

9. On or about October 5. 1990, CISNEROS made a payment to MEDLAR in the amount of $4,000.

10. On or about October 12, 1990, CISNEROS made a payment to MEDLAR in the amount of $5,100.

11. On or about November 1, 1990, CISNEROS made a payment to MEDLAR in the amount of $3,000.

12. On or about December 4, 1990, CISNEROS made a payment to MEDLAR in the amount of $4,000.

13. On or about December 8, 1990, CISNEROS made a payment to MEDLAR in the amount of $4,000.

14. The total of the payments made by CISNEROS to MEDLAR in 1990 was approximately $44,500.

1991 Payments

1. On or about January 9, 1991, CISNEROS made a payment to MEDLAR in the amount of $6,000.

2. On or about February 2, 1991, CISNEROS made a payment to MEDLAR in the amount of $4,000.

3. On or about February 26, 1991, CISNEROS made a payment to MEDLAR in the amount of $12,000.

4. On or about April 17, 1991, CISNEROS made a payment to MEDLAR in the amount of $4,000.

5. On or about April 18, 1991, CISNEROS made a payment to MEDLAR in the amount of $4,000.

6. On or about May 1, 1991, CISNEROS made a payment to MEDLAR in the amount of $4,000.

7. On or about May 31, 1991, CISNEROS made a payment to MEDLAR in the amount of $4,000.

8. On or about July 3, 1991, CISNEROS made a payment to MEDLAR in the amount of $4,582.

9. On or about July 18, 1991, CISNEROS made a payment to MEDLAR in the amount of $2,500.

10. On or about August 2, 1991, CISNEROS made a payment to MEDLAR in the amount of $4,000.

11. On or about October 2, 1991, CISNEROS made a payment to MEDLAR in the amount of $4,500.

12. On or about November 5, 1991, CISNEROS made a payment to MEDLAR in the amount of $3,925.

13. On or about December 2, 1991, CISNEROS made a payment to MEDLAR in the amount of $4,000.

14. On or about December 31, 1991, CISNEROS made a payment to MEDLAR in the amount of $2,500.

15. The total of the payments made by CISNEROS to MEDLAR in 1991 was approximately $73,000.

1992-1993 Payments

1 . On or about March 2, 1992, CISNEROS made a payment to MEDLAR in the amount of $3,000.

2. On or about April 3, 1992, CISNEROS made a payment to MEDLAR in the amount of $2,500.

3. On or about May 5, 1992, CISNEROS made a payment to MEDLAR in the amount of $4,000.

4. On or about June 2, 1992, CISNEROS made a payment to MEDLAR in the amount of $2,500.

5. On or about July 6, 1992, CISNEROS made a payment to MEDLAR in the amount of $2,500.

6. On or about August 3, 1992. CISNEROS made a payment to MEDLAR in the amount of $4,000.

7. On or about September 2, 1992, CISNEROS made a payment to MEDLAR in the amount of $2,500.

8. On or about December 3, 1992, CISNEROS made a payment to MEDLAR in the amount of $4,000.

9. On or about December 16, 1992, CISNEROS made a payment to MEDLAR in the amount of $8,000.

10. On or about December 18, 1992, CISNEROS made a payment to MEDLAR in the amount of $8,000.

11. The total of the payments made by CISNEROS to MEDLAR in 1992 was approximately $67,500.

12. On or about January 4, 1993, CISNEROS made a payment to MEDLAR in the amount of $4,000.

B. Payments To Medlar During Cisneros's Tenure As HUD Secretary

1. On or about January 28, 1993, CISNEROS made a payment to MEDLAR in the amount of $5,000.

2. On or about February 10, 1993, CISNEROS made a payment to MEDLAR in the amount of $7,500.

3. On or about February 16, 1993, CISNEROS made a payment to MEDLAR in the amount of $ 15,000.

4. On or about February 24, 1993, CISNEROS made a payment to MEDLAR in the amount of $15,000.

5. On or about March 15, 1993, CISNEROS made a payment to MEDLAR in the amount of $10,873.45.

6. On or about July 16, 1993, CISNEROS made a payment to MEDLAR in the amount of $ 15,000.

7. On or about October 12, 1993, CISNEROS made a payment to MEDLAR in the amount of $4,000.

8. The total of the payments made by CISNEROS to MEDLAR in 1993 was approximately $79,500.

Cisneros's Nomination And Confirmation As Secretary Of HUD

1. On or about December 17, 1992, President-elect Clinton publicly announced his intention to nominate CISNEROS to be Secretary of HUD.

2. On or about December 29, 1992, in accordance with the terms of the MOU, and as part of one of its lawful, authorized, governmental functions, the FBI began a full-field background investigation of CISNEROS.

3. On December 30, 1992, as part of the FBI's background investigation of him, CISNEROS was interviewed by a Special Agent of the Federal Bureau of Investigation.

4. On January 7, 1993, as a result of information developed during the course of its background investigation of CISNEROS, and based upon CISNEROS's responses during the course of the December 30, 1992 FBI interview, CISNEROS was interviewed by Special Agents for the Federal Bureau of Investigation for a second time.

5. On January 12, 1993, pursuant to its constitutional advice and consent power and responsibility, the Senate Banking Committee held hearings regarding CISNEROS's nomination to be Secretary of HUD.

6. On or about January 21, 1993, CISNEROS was formally appointed and confirmed as Secretary of HUD.

Cisneros's Position Of Public Trust

1. As Secretary of HUD, CISNEROS was the senior official in charge of the Department of Housing and Urban Development, a member of the President's Cabinet, and twelfth in line to succeed the President of the United States, should it have become necessary.

2. As Secretary of HUD, CISNEROS was entrusted by the United States Congress and the United States taxpayers with the responsibility of overseeing an annual budget of approximately twenty billion dollars.

3. As Secretary of HUD, CISNEROS was responsible for and required to exercise personal leadership in establishing, maintaining, and carrying out HUD's ethics program, a principal part of which included adherence to the Code of Federal Regulations' Standard of Ethical Conduct for Employees of the Executive Branch.

4. As Secretary of HUD and a Cabinet Officer, CISNEROS was an employee and official of the United States. As such, he held a position of public trust and thus had a responsibility to the United States, its citizens, the officers and employees of the Administration, and HUD, to abide by the following general principle, among others, set forth in the Code of Federal Regulations' Standards of Ethical Conduct for Employees of the Executive Branch, 5 C.F.R. 2635: "Public service is a public trust, requiring ... loyalty to the Constitution, the laws and ethical principles."

5. That public trust included duties (a) to obey the criminal and civil laws of the United States and (b) to disclose to the government, including officers and employees of the Administration, material information as required by law.