From the Chicago Tribune

We don't have to prove Ryan took an outright payoff, prosecutors say
By Mike Robinson
Associated Press Writer
Published September 1, 2005
Prosecutors argued Thursday that they don't have to prove former Gov.
George Ryan took payoffs to make mail fraud charges against him stick
at his upcoming trial.
In court papers, prosecutors cited a recent interview in which Ryan
said that "the federal government can't name one person who gave me a
corrupt dollar."
Prosecutors said they don't have to show a specific sum of cash
changing hands to prove the mail fraud charges and asked federal Judge
Rebecca R. Pallmeyer to make that clear to the jury.
The indictment accuses Ryan, among other things, of getting free
vacations from a businessman who later got a state lease and loans for
his brother's business from a lobbyist.
Prosecutors said it would be enough to show that Ryan failed to
provide the state with his "honest services" because he was being
influenced by something that stopped short of an outright bribe.
"The law does not require such evidence of cash or a specific quid pro
quo to establish liability for 'honest services' mail fraud," said an
eight-page brief filed with Pallmeyer.
Ryan attorney Dan K. Webb did not return a message seeking comment. An
aide said Webb was out of town.
Ryan is accused of engaging in corrupt activity when he was Illinois
secretary of state with lobbyist friend Larry Warner, who is now his
co-defendant in the case.
Warner had no official role in the secretary of state's office, but
Ryan is charged with giving the lobbyist free reign to steer big-money
state contracts and leases to his clients.
Ryan has denied any wrongdoing and Warner's attorneys are expected to
argue at the trial, which is due to begin Sept. 14, that there was
nothing illegal about any lobbying fees he got.
The case is part of the eight-year-old Operation Safe Road, which
began by focusing on bribes paid for drivers licenses and expanded
into a wide-ranging political corruption probe.
Ryan and Warner are jointly charged in seven mail fraud counts. Ryan
is charged in two more.
Prosecutors said in their filing that Ryan performed and authorized
official acts to benefit his, Warner's and others' financial
interests. They also claimed "Ryan received personal and financial
benefits from Warner and others while knowing that such benefits were
provided with intent to influence and reward Ryan in the performance
of official acts."
But prosecutors said there was no need for them to prove Ryan took a
specific payoff.