Defendant Steve Stenger Sentencing Memorandum

Case: 4:19-cr-00312-CDP Doc.
#: 43 Filed: 08/02/19 Page: 1 of 12 PageID #: 208
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
UNITED STATES OF AMERICA, )

)
Plaintiff, )
) NO. 4:19 CR 00312 CDP
v. )
)
STEVEN V. STENGER, )
)
Defendant. )
GOVERNMENT’S SENTENCING
MEMORANDUM
Comes now the United States of America, by and through Reginald Harris, Attorney for
the United States, and Hal Goldsmith, Assistant United States Attorney for the Eastern District
of Missouri, and for its Sentencing Memorandum, states to this Honorable Court as follows:
1. By any standard or measure, defendant Steven Stenger’s criminal conduct calls
for a significant prison sentence. Application of the United States Sentencing Guidelines here
advises a sentence of 37 to 46 months’ imprisonment. Anything less would ignore the extent of
defendant’s criminal conduct and the substantial harm defendant’s conduct caused to the public.
2. Title 18, United States Code, Section 3553(a) sets out the factors this Court
should consider in fashioning an appropriate sentence. The first such factor to be considered is
the nature of the offense, 18 U.S.C. 3553(a)(1). St. Louis County, Missouri is the largest county
and political subdivision in Missouri, with approximately 1,000,000 residents. In comparison,
Jackson County, the state’s second largest county, has approximately 700,000 residents (which
includes 480,000 residents who reside within Kansas City), and St. Louis City has
approximately 330,000 residents. The approximately 1,000,000 residents of St. Louis County
all depended upon defendant Stenger to do the right thing as the elected County Executive, and
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Case: 4:19-cr-00312-CDP Doc. #: 43 Filed: 08/02/19 Page: 2 of 12 PageID #: 209
to provide them with his honest services. Through his extensive criminal conduct he abused
their trust in a substantial and harmful way. He placed his own personal interests and political
ambitions above all else, and engaged in a classic illegal pay to play scheme in order to fill his
own political coffers to fuel his political campaigns. Defendant’s criminal acts were for his own
personal gain, aimed at continuing his reign of power and authority in St. Louis County and,
because of the county’s significant population base, throughout the entire region and state.
3. This Court need only look to the language of the Grand Jury’s Indictment
returned in this case to get a clear picture of the nature and extent of defendant’s criminal
conduct. Defendant used his position to reward political donors with contracts and grants,
requiring subordinate employees who depended upon him for their jobs to take actions which
were illegal and unethical, many times with the threat of termination, express or implied,
hanging over the employees’ heads. Defendant’s criminal conduct relative to his pay to play
scheme began even before he was first sworn in as County Executive in January, 2015, when,
on November 25, 2014, following his election, defendant directed the CEO of the St. Louis
Economic Development Partnership to extend a lobbying contract to one of defendant’s
significant political donors. (Indictment at paragraph 31) Defendant’s pay to play schemes
continued throughout the entirety of his tenure as County Executive, at least through December,
2018 when he directed three members of his executive staff, and the CEO of the St. Louis
Economic Development Partnership, to once again ensure the extension of the lobbying contract
on behalf of the very same political donor, identified as the owner of “Company One” in the
Indictment. In many contracting situations there were one or more competing bids, and
defendant’s directive to award the contract to a political donor disadvantaged the competing
bidders, as, for example, in the December, 2018 lobbying contract situation. Those individuals
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and companies that submitted bids expecting a level playing field were also victimized by
defendant’s pay to play scheme. It is abundantly clear from the evidence gathered in this case
that one of defendant’s primary concerns was that his political donors receive the desired
contract or grant, and that he continue to personally win politically.
Defendant often appointed Board Members who he knew would take their direction from
him in order to carry out his directives. For example, defendant appointed his Chief of Policy
and his Chief of Staff, along with several other “friendly” individuals, to the Board of the St.
Louis Economic Development Partnership. Defendant recommended Sheila Sweeney be
appointed as CEO of the Partnership because he knew he could manipulate and control her, as
he did relative to the Cardinal Consulting contract through the Port Authority and the Wellston
Holdings land deals through the LCRA. Defendant’s actions and conduct were aimed at
ensuring that his directives in favor of his political donors were followed.
Defendant’s “politics” is what mattered to him. He directed that political cronies and
their family members be hired by St. Louis County as part of his effort to maintain his political
position, and to continue his scheme. As he told his executive staff on January 4, 2019, when
discussing his desire that the County Council not know which of the numerous department
budgets his various non-merit hires were being paid from:
“That’s one of the greatest powers I have. That I have 52 people

who I hire and nobody knows where they’re coming from. For
instance, there are 2 slots over at the jail. Nobody knows if Julia
Childrey [Director of Department of Justice Services] put those
people there, or I did. It’s good f---ed up. We like it f---ed up. I
care about my politics.”
Defendant’s pay to play scheme in which he collected hundreds of thousands of dollars
in political donations for his own benefit was not only criminal, but also reveals a flagrant
disregard for the interests of those he was elected to serve. It matters not that the bribes were in
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the form of campaign donations, and not direct payments to defendant. The fact that he used
the bribes to fuel his political campaigns freed up his own funds to use for his own personal
lifestyle. For example, in the early years of his political career, defendant found it necessary to
loan his campaign account approximately $400,000. Through his political fundraising and
criminal scheme, following the November, 2018 general election he was able to pay himself
back that $400,000 directly out of his campaign account. For over four years he treated
important government contracts and grants as something to barter away as if they were his own
personal thank you gifts. Looking at the nature and circumstances of defendant’s offenses under
any imaginable standard, this Court should view them as serious offenses.
4. The next factor to be considered by this Court in sentencing defendant are the
history and characteristics of defendant, 18 U.S.C. 3553(a)(1). As to defendant’s history and
characteristics, one need only look to the year 2018, the most recent year of defendant’s tenure as
County Executive, to understand that defendant placed politics and personal gain over the needs
of the residents he was sworn to serve. In addition to his criminal conduct, Stenger “checked out”
during 2018, spending little time in his County Executive office, while most of his focus was on
fund raising for his own August primary and November general elections. As he told his executive
staff in a private conversation on November 7, 2018, following the general election:
STENGER: “How ‘bout that motherf---ers? I don’t show up to the

Council meetings. I don’t do f---ing shit. I’ve been sitting at my
house for the past two months f---ing raising money and then won
by 20%! The world’s a f---ed up place.”
During 2018, in addition to fund raising, Stenger also spent a considerable amount of his
time planning and advocating for the merger of St. Louis City and County, a plan put forth by an
organization known as Better Together. Better Together’s ultimate plan to merge the City and
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County required an Amendment to the Missouri State Constitution, anticipated to be put to
Missouri voters during 2020.
The operations and activities of Better Together which were aimed at the consolidation of
St. Louis City and County were funded, primarily, by financier Rex Sinquefield. Sinquefield was
a major donor to Stenger’s 2018 re-election campaign, contributing approximately $700,000
through various of his own organizations and political action committees to Stenger’s political
efforts. Defendant Stenger was motivated to seek re-election as County Executive during 2018 in
large part by his desire to be named Metro Mayor in Better Together’s consolidation plan, as
discussed in a private conversation with his executive staff on October 9, 2018.
STENGER: “And in my second term I really don’t want to do

anything, I just don’t. If we don’t get 2020 done I’d have to
reevaluate, I don’t know if I want to do another four years, it just
depends what it looks like.”
In order to further tie himself to the Better Together merger plan, during October, 2018,
defendant Stenger directed that the husband of Rex Sinqefield’s chief of staff be hired by St. Louis
County, and given the title of “senior policy advisor for administration and strategic initiatives.”
At defendant Stenger’s direction, this individual (referred to here as “John Doe”) was paid
$130,000 per year in his St. Louis County position. Unbeknownst to John Doe, defendant Stenger
advised his executive staff in a November 7, 2018 private conversation that he hired John Doe to
personally benefit from his own relationship with Better Together.
November 7, 2018:
STENGER: “I have aligned myself, the very best way you can be
aligned with these guys [Better Together], which is like John Doe,
which is like, I’ll explain it to both of you [William Miller and Jeff
Wagener] in person. John Doe is here for one reason and one reason
only. John Doe is an insurance policy. His wife is working for Rex,
it’s a good faith effort on my part, I’m saying, hey look at, I’m
willing to hire John Doe at 130 Grand. She’s Rex’s assistant. Kind
5
of sends a message to all of them that I trust them. And they’ve

done a lot to demonstrate that they trust me and they should.
They’ve given me a lot of money, they’re almost up to like 700
Grand.”
When defendant Stenger’s executive staff complained about John Doe, Stenger advised his staff
in a November 8, 2018 private conversation:
STENGER: “I just want him to shut up, and make your 130 Grand
and leave everybody alone. Quit doing what he’s doing. If he
doesn’t like it, I guess he could go somewhere else, but I’d rather
have him stay, then I can get my money. Just enjoy himself, enjoy
the chain of command. Some people are here because they’re
married to the Chief of Staff of Rex Sinquefield, and you’re one of
them. Calm down.” 1
Thus, just as defendant directed contracts to his political donors in his criminal pay to play scheme,
his desire to continue receiving political fundraising support drove his advocacy on behalf of the
Better Together plan, not a desire to serve the people. Further, defendant Stenger was motivated
to advocate for Better Together’s merger plan by the fact that the St. Louis County Council, whose
Members had been in conflict with Stenger for months, would no longer exist in a merged
Metropolitan City. Stenger told members of his executive staff in a November 7, 2018 private
conversation:
STENGER: “The only thing that’s really going to kill these guys
[St. Louis County Council Members] is what’s coming in 2020. I’m
telling you, we all need to embrace the f--- out of this. Embrace it.
I mean embrace it. We’ve got to pray that we pass this f---ing
thing….This answers a lot of our f---ing problems. Who wants to
do another term with these people? I’d rather wipe them out.”
In the final analysis, as in his pay to play scheme, defendant was motivated to support the Better
Together merger plan for all of the wrong personal reasons, with no concern for the residents of
1
Despite John Doe’s efforts to work on County projects following his hiring, he was assigned
very little substantive County work by Stenger or Stenger’s Chief of Staff, Bill Miller, and he
worked primarily on Better Together matters, while being paid with St. Louis County funds.
6
St. Louis County. As Stenger told executive staff members and close associates in private
conversations:
November 7, 2018:
STENGER: “We’re pretty solid with leadership, with me being the

person. I’m trying to get the Amendment to be drafted so I’m the
leader. I’m just being overly cautious because I don’t want some f-
--ing last minute change f--- me over.”
* * * *
December 6, 2018:
STENGER: “I could give a f--- about 2020. I’m in the amendment.

People are going to have me whether they like me or not….”
In further considering defendant’s history and characteristics, throughout his tenure as
County Executive, Stenger let his drive for personal political gain control his actions, as opposed
to doing what was in the best interest of St. Louis County. When a St. Louis County employee, a
company seeking to do business with St. Louis County, or someone in the political world took an
action which Stenger viewed as adverse to his own political ambitions or as undercutting his
authority and position of power as County Executive, he advocated strong retribution against that
individual or company, including the threat of termination when it was a County employee. Just
as defendant favored his political donors in his criminal pay to play scheme, defendant looked to
punish those who crossed him politically or who refused to carry out his directives. As noted in
the Indictment and in defendant’s Plea Agreement, when St. Louis County’s Director of
Administration, Pamela Reitz, refused to comply with Stenger’s directives to issue contracts to his
political donor John Rallo’s insurance company, Stenger threatened to fire her.
Another example involved the St. Louis County Counselor. During November 2018, St.
Louis County voters overwhelmingly approved Proposition Z which increased County sales taxes
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for a St. Louis Zoo development initiative. The State of Missouri Department of Revenue,
however, raised a question concerning the legality of the increased sales tax. The St. Louis County
Counselor then issued a legal opinion that the Proposition Z sales tax, passed by the voters, was
appropriate and legal. Stenger, upset that the County Counselor had issued the legal opinion in
support of the proposition, threatened to terminate him. Stenger discussed the issue with members
of his executive staff on January 2, 2019:
STENGER: “This jackoff [County Counselor] does not understand

he was appointed by me. Everything he does comes back on
me….Why would you ever give a legal opinion without talking to
your boss. I’m his boss. If you don’t think I’m your boss, you’re
going to find out in about 10 f---ing seconds….I’m the boss.
F---ing don’t issue a legal opinion again without me or I’ll fire your
f---ing ass. I’m f---ing done with that guy, I really am done….I’m
not going to have a County Counselor who’s not mine….I appointed
him for a reason, because he’s mine. We even talked to him about
it, who f---ing cares, we were all happy if the Zoo didn’t get the
f---ing tax. I don’t care. I hope they don’t. I really don’t f---ing
care. It does nothing for me.”
A further example involved a significant minority contractor in the St. Louis area whose
mother is a former Missouri State Representative. Stenger was supporting St. Louis County
legislation that would fund the expansion of America’s Center in downtown St. Louis. The
proposed expansion would create substantial construction jobs for area companies. Relative to the
America’s Center expansion project, Stenger advised his executive staff on December 3, 2018,
that the contractor would not receive any work on the project solely as a result of his mother’s
political actions:
STENGER: “We’re not going to advance our bill if [Contractor] is

anywhere near this thing, it’s not happening. Not. His f---ing Mom
did commercials against me. If we let that go, we’re just the f---ing
pussies of the universe. It’s not going to happen. It sends a message
to him. F--- you. And to her, f--- you. He just lost out on probably
2% of a giant project. I mean, literally, that’s 7 Million Dollars to
him.”
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As previously noted, during 2018 there was significant conflict between defendant Stenger
and Members of the St. Louis County Council. The Chair of the County Council during 2018 was
Dr. Sam Page, and Stenger and Dr. Page often were at odds with each other. A further example
of Stenger’s vindictive nature and character while serving as County Executive involved Dr.
Page’s employment as a physician. Stenger discussed Dr. Page in a private discussion with
members of his executive staff on October 19, 2018.
STENGER: “I’m going to meet with the head of [Page’s Employing

Hospital] and let him know what’s going on with Sam. I think he
already knows, but I’m gonna tell him, look man, there’s nothing
personal, but this is gonna get real personal with Sam over the next
two years, so you may not want him at your f---ing place any more.
Get him fired. I’m serious too. It’s serious. I’m gonna f---ing
unload on this guy, professionally….”
5. This Court’s sentence should also afford adequate deterrence to criminal conduct,
18 U.S.C. 3553(a)(2)(B). This defendant was the duly elected County Executive for St. Louis
County. He was charged with overseeing and running the operations of that public entity on
behalf of its one million residents. Defendant also exercised considerable authority and influence
over the County’s affiliated organizations, including the St. Louis Economic Development
Partnership, the St. Louis County Port Authority, and other similar organizations. This Court
should fashion a significant punishment not only to deter this defendant from future criminal
conduct, but in order to deter other individuals in similar governmental positions from
committing similar crimes. The government submits that a significant prison sentence in this
case will have that desired deterrent effect.
6. Upon being indicted by the Grand Jury for the instant offenses, defendant took
several actions. He resigned his position as County Executive, and surrendered his Missouri
law license and his CPA license. Within 5 days following his arraignment, defendant pled guilty
9
to the Indictment. The government submits that defendant’s guilty plea was the result of the
overwhelming evidence against him, of which he and his counsel were aware. Defendant’s law
license would have been suspended pending full disbarment proceedings based upon the charges
and conviction in this case. He would have ultimately been barred from the practice of law for
a minimum of five (5) years by the Missouri Supreme Court. Likewise, defendant’s position as
County Executive would have been terminated based upon the charges and conviction in this
case. Defendant has been awarded acceptance of responsibility under the United States
Sentencing Guidelines in this case as a result of his guilty plea. The fact that he resigned his
elected position and surrendered his law license should not be the basis for any further
sentencing benefit in this case. In a public corruption case such as this, removal from public
office or resignation from one’s elected position is the ordinary and inevitable result. Similarly,
a practicing attorney who commits these types of crimes will have his license suspended and
will be barred from the future practice of law. There is nothing extraordinary about defendant’s
actions in this regard. Any suggestion by defendant that the surrender of his law license, and
his resignation from elected office should inure to his benefit at sentencing should be rejected
by this Court. Instead, this Court should hold this defendant to a higher standard of conduct
precisely because of defendant’s status as a licensed attorney and his position as having been
the highest elected official in the largest county in the State of Missouri. If the Court were to
consider these collateral consequences in framing a more lenient sentence, it would be
tantamount to favoring criminals with privileged backgrounds.
7. Defendant has an advisory guideline sentence under the United States Sentencing
Commission Guidelines of 37-46 months in prison. The government submits that there is no
basis whatsoever in the law or the underlying facts and circumstances here that would justify a
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downward variance to a sentence less than the advisory guideline sentence. It is the
government’s position that justice and fairness require a significant sentence of imprisonment
in this case. As a direct result of defendant’s criminal conduct, the adverse impact upon St. Louis
County and its residents who rely upon their elected officials to perform their jobs honorably
and with integrity has been substantial. This is not a victimless crime. The defendant’s pay to
play scheme, which went on for many years and impacted many contracts and grants, was aimed
at illegally filling his political coffers so that he could maintain his position of power and
authority, all to the detriment of the County’s residents. Our public officials should be held
accountable for their criminal conduct by appropriate prison sentences; the victim residents
deserve it, and fairness and justice require it.
8. In fashioning an appropriate sentence here, this Court needs to have a full and
clear understanding of the adverse impact defendant’s criminal conduct has had on the residents
of St. Louis County, St. Louis County Government, and the St. Louis Economic Development
Partnership and its affiliated organizations, the St. Louis County Port Authority and the Land
Clearance for Redevelopment Authority of St. Louis County. Attached as Government Exhibits
1 - 4 to this Sentencing Memorandum are four (4) letters which articulate in a way that the
undersigned cannot the truly substantial and harmful impact that defendant’s criminal conduct
had upon these individuals and entities. How does one even begin to measure the loss of trust
in its leaders by the citizens of St. Louis County as a result of defendant’s crimes?
9. Only a significant prison sentence will adequately reflect the seriousness of the
offense, promote respect for the law, and provide just punishment for defendant’s criminal
offenses as is required by 18 U.S.C. 3553(a)(2)(A). As President Roosevelt said:
There can be no crime more serious than bribery. Other offenses

violate one law while corruption strikes at the foundation of all
11
law. Under our form of Government all authority is vested in the

people and by them delegated to those who represent them in
official capacity. There can be no offense heavier than that of him
in whom such a sacred trust has been reposed who sells it for his
own gain and enrichment….
Theodore Roosevelt, Third Annual Message to the Senate and House of Representatives (Dec. 7,
1903). Those words are as meaningful and applicable today, in the instant case, as they were when
uttered 116 years ago. After all, public service is a public trust. Defendant broke that trust here
and should be justly punished.
WHEREFORE, the United States of America prays that this Honorable Court sentence
defendant to an appropriate term of imprisonment within the advisory guideline range, without a
downward variance, and for such other relief as this Court deems appropriate and just under the
circumstances.
Respectfully submitted,
REGINALD HARRIS
Attorney for the United States
/s/Hal Goldsmith
HAL GOLDSMITH #32984MO
Assistant United States Attorney
111 S. 10th Street, Room 20.331
St. Louis, Missouri 63102
(314) 539-2200
CERTIFICATE OF SERVICE
I hereby certify that on August 2, 2019, the foregoing was filed electronically with the
Clerk of the Court to be served by operation of the Court’s electronic filing system upon the
defendant’s counsel of record.
/s/ Hal Goldsmith

HAL GOLDSMITH, #32984MO
Assistant United States Attorney
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Case: 4:19-cr-00312-CDP Doc. #: 43-1 Filed: 08/02/19 Page: 1 of 6 PageID #: 220
Exhibit 1
ST" L UIS COUNTY
July 24, zotg
Honorable Catherine D. Perry

United States District Court for the Eastern District of Missouri
rrr South roth Street
St. Louis, Missouri 6groz
R:e: United States u. SteuenV. Stenger, Case No. 4:t9CR3rz CDP/NCC

Dear Judge Perry:
As elected representatives of St. Louis County government, we are jointly writing

to sumtnarize the defendant's negative impact on our County and its residents. This
letter reflects our collective experience, as well as the experience of several County
employees, appointees, residents, and other impacted individuals, facts we uncovered
when we asked them to describe their experiences with the defendant. We hope this will
assist you in deciding the fair and just sentence to impose in this case.
The defendant's behavior had a devastating impact on St. Louis County. The
defendant's criminal conduct speaks for itself, but the impact of his behavior goes far
beyond the facts described in the indictment. For five years, the defendant bJhaved as if
he was an untouchable king, particularly as he began to believe he would continue in
office as the unelected "Metro Mayor" of a newly-combined regional government.
Throughout his tenure, the defendant created and fostered a working environment for
County employees and other elected officials that was marked by fear, intimidation,
manipulation, and retribution.
The defendant con the good of St. Louis County.

Early in his administratio "If you haven,t figured it out
y_et, I'1n only interested in at benefit me." This remark u/trre
defendant seemed to summarize the experiences many of his staffhad witlr-him. If a
e very interested in it. There is perhaps
dollars to raise an unprecedented sum
The defendant treated any official decision
ost important policy prioritybut ignored
everything erse.
As a chief executive and leader, the defendant failed in dramatic fashion. His
former staffmembers are Ieft feeling betrayed, used, demoralized, and disillusioned.
ADMINISTRATION BUILDING . 4 I S, CENTRAL AI/EMIE . CLAWON, MISSOUN 6 3 I 05

The County Govemment Center and the Council Chamber are accessible for persons with disabilities, If you need an accomodation or
need this material in an altemative format, please call Genevieve Frank, Adminishative Director, at (314) 615-5440 (voice) or call
RelayMO 7ll or l-800-735-2966 (TTY). FaxNumber: 314-615-7890
Hon. Catherine D. Perry

July z4,zot9
Page Two
The work atmosphere the defendant embraced was more that of a fraternityhouse than
an elected official's office. The defendant rarely appeared in his office, and would be
absent for weeks at a time. He did not respect the dignity of his office. When he did
come to work, he typically arrived late in the day wearing shorts, a t-shirt, and a baseball
hat, and then he would immediately close the door and spend much of the day playing
video games in his office before leaving early. He ignored offensive behavior. On at
least three different occasions, each involving a different female employee, the
defendant was present during instances of sexual harassment or learned of the instance
shortly after the conduct occurred, but the defendant never took investigative or
disciplinary action to rectify the situation. Literally laughing in the face of overt sexual
harassment by campaign contributors and reporters, the defendant encouraged an
atmosphere where victims were without a voice and felt that they could not go to the
County Executive to report inappropriate behavior.
The defendant's criminal enterprise put dedicated public employees in difficult if

not impossible positions. The defendant's scheme often required County employees to
act unethically, and sometimes put them in positions with such limited information that
they could not have known then that what they were being told to do was inappropriate.
County employees were trapped, knowing that their refusal to comply would result in
termination or forced resignation. The attendant loss of tenured, experienced, and
professional expertise left a lasting imprint on Countygovernment that is significant
and widespread.
Some of the roughly 4,ooo County employees stood up against the defendant,
and their courage and adherence to high ethical standards must be acknowledged. But
many other employees were held hostage by a criminal, forced to choose between
leaving for a less toxic work environment and remaining, accepting the stress and
anxiety of hoping they would not be caught up in the defendant's corrupt behavior or
unwittingly drawn into an illegal activity. Those who stayed as employees took home
the stress, anxiety, depression, and anger, which can spread like an infective virus to
friends and families, helping to create a hopelessness that St. Louis County would never
move forward or address our real problems: racial inequities, economically devastated
communities, lack of opportunity, and so many more.
The defendant thrived on division. He tried to divide the County Council, pitting
one Council member against another. He tried to divide Democrats from Republicans,-
Democrats from other Democrats, and Republicans from other Republicans. He pitted
nurses against police officers, unions against other unions, and everyday people against
his campaign contributors. Sometimes it seemed Steve Stenger couid nbf gef alo"Ig *itt
any_one_ except his campaign donors. And he certainly got along well with ihem. In the
end, other than with the defendant's_campaign contributors, thi defendant's leadership
style made County government largely dysfunctional, unpredictable, and hamstrung.

July 24, zotg
Page Three
The defendant's contentious relationships are legion, and they severely hampered
our region's progress. The defendant's personal animosityfor John Nations, the former
leader of Bi-State Development Corporation ("Bi-State"), his petty jealousy of former
Mayor Francis Slay, his contempt for his colleagues on the County Council, and his
hatred for anyone he saw as crossing him led to stalled budgets, wasted ta4payer dollars,
and thwarted opportunities for regional collaboration. For instance, Bi-State long had
the opportunity to refinance its debt and use any savings to implement new Metrolink
security strategies, but the defendant refused to approve the refinancing solely as a
result of his personal pique with Bi-State's leader. The opportunltyto refinance Bi-
State's debt was but one of the countless opportunities that St. Louis County missed as a
result of the defendant's behavior.
He often scoffed at the expectation that he perform the duties of his office, and he
adamantly refused to lead on the important issues of the day. The defendant's
sentencing hearing is scheduled to ol",rr the week of Augusi 9, the fifth anniversary of
Michael Brovvn's death in Ferguson. Five years ago, the world's eyes focused on St.
Irgit County. Taking office shortly thereafter, the defendant faced a County needing
real leadership, but he refused to engage genuinelywith the African-American
community and he chose simply to ignore the vexing challenges that faced County
residents.
_ Similarly, the defendant's dismissal of decisions regarding the county's day-to-

day-management and operations left the Countyparalyzed to addressing ongoing
challenges. His ilattention to Animal Care and Control's operations left it in disirray.
His failure to lead the Justice Center to implement new policies and practices left it in a
chaotic state. His failure to address desperate budget issues, his disregard for his own
budget director's advice, and his order that departments ignore the need for budget cuts
left the Countywith an annual operating deficit of several million dollars. His refusal to
engage with the community resulted in the federal government pushing the County
toward demolishing public housing units in Wellston. The defendant's lack of attention,
care, and compassion almost led to the displacement of hundreds of Wellston residents,
Tany of which were children who could have been left homeless. In each instance, the
defendant ignored an issue where he did not see a monetarybenefit for himself or for
his political campaign. selfish priorities left these and many other important policy
-His
decisions unaddressed for years.
ay-to-play e
and wide.
candidate the
countyboards and commissions. Each
"r,h#;'jf,-?*:1':t::::r':ilill"Trl'Ji:ll"*
County-these are just some of the results of St. Louis County's damaged biand.

July 24, zotg
Page Four
The defendant's systemic "pay-to-play" scheme also severely compromised St.

Louis County's brand as a place for economic development and investment. The
defendant told potential developers and potential Countyvendors that theywould
"never get County business" if their proposal failed to benefit the defendant. The
reputation for "pay-to-play" behavior has discouraged ethical developers from planning
projects in the County and has discouraged ethical vendors from bidding on County
contracts. We do not yet know the full extent of the financial damages, but we know
that the financial toll and opportunity costs to the County over the coming years are
significant and may be incalculable.
The defendant's conduct has taken its toll on so many good people of strong
moral character and respectable reputations who-despite their best judgment-trusted
the defendant, contributed to his campaigns, sought his help,lobbied him, or served as
one of his staffmembers, advisors, contractors, or consultants. Many of those people
knew nothing about the defendant's criminal conduct and would not have approved of it
had they known. Nevertheless, they are left with the taint of being associated with Steve
Stenger. Many are unable to find work, form partnerships, or attract clients. Some are
connected to him in media reports despite their own innocence. The financial,
psychological, and personal costs these individuals sustained are impossible to quantifz;
money cannot compensate for their losses. It may be impossible to restore the
reputations of some innocent, well-intentioned people whose only desire was to engage
in public service and were shocked to find themselves working for a criminal.
_ The County also sustained significant financial losses resulting from contracts
and agreements negotiated and entered into at the defendant's behest. The loss of this
capital will have long-term effects on the liquidity, viability, and economic health of the
County. The defendant's unbridled control of the Economic Development partnership
and Port Authority, as described in the indictment, shows his misus-e of public assets ior
personal and political gain. As a result, real estate owned by St. Louis County either was
sold to Stenger campaign contributors inappropriately or remains unsold because
potential buyers refused to "pay up." The defendant appointed individuals with
histories of opposing minority-owned and woman-o*nid businesses participation in
procuring contracts for County business. As a result of the defendant;s misute of
development agencies, some leaders in the City of St. Louis have threatened to remove
the City from the Economic Development partnership.
The defendant's behavior also impacted the general public. Our constituents lost
trust in County Sovernment, its elected ofEcials, and in the democratic process as a
whole.- Taxpayers saw public funds spent to reward political supporters rather than
serve the public good. The defendant's lasting impait on Counfr government,s
reputation has rendered restoring trust in Countygovernment to be a generational
challenge.

July 24, zotg
Page Five
In the final analysis, the defendant never behaved as if he appreciated or even

understood the significa- ce of his office. He never grasped the true meaning of public
service. He was not a public servant. He violated the public trust and his oath of office.
The defendant dug an enormous hole for St. Louis County. The undersigned are
committed to working together in pulling our County out and moving forward with a
positive vision for the future. But we write now to express our hope that the Court order
a sentence that recognizes the immense negative impact Steve Stenger had on St. Louis
County and orders restitution to compensate the people of St. Louis County for his
crimes.
Sincerely,
Sam Page G
County Executive Officer, County Council
Walton Gray Harder

District 4 District 7
Tim Fitch
5 District 3
Exhibit 2
STLPARTN RSH P
August L,2O!9
The Honorable Catherine D. Perry

U.S. District Court for the Eastern District of Missouri
111 South 10th Street
St. Louis, MO 63102
Re: lJnited Stotes of Americo v. Steven V. Stenger, Cause No. 4:19CR312

United Stotes of Americo v. Sheilo A. Sweeney, Cause No. 4:19CR375
Dear Judge Perry:
ln accordance with pleas entered by Steven V. Stenger and Sheila A. Sweeney, the defendants in the above
referenced cases (together, the "Defendants"), the St. Louis Economic Development Partnership (the
"Partnership") is a victim of crimes committed by Stenger and Sweeney. Please accept this letter as a
statement on behalf of the Partnership under 18 U.S.C. 5 377L.
The Partnership (formerly known as the St. Louis County Economic Council) is a non-profit corporation
formed, in 1984, under Missouri law and is the regional economic development agency for St. Louis. ln
2013, the Partnership adopted its current name and consolidated certain economic development
activities of St. Louis County and St. Louis City. The County Executive appoints eleven Directors to the
Partnership's Board; the Mayor of the City of St. Louis appoints four. All but a small portion of the
Partnership's activities are funded with public money. The Partnership also administers numerous
economic development political subdivisions and corporations including the St. Louis County Port
Authority ("Port Authority") and the Land Clearance for Redevelopment Authority of the County of St.
Louis ("LCRA").
The corruption scheme Stenger and Sweeney devised and executed, as described in their guihy pleas,
caused substantial direct financial loss to the Partnership, including the following:
a Public contracts awarded to private parties at the direction of Stenger and approved by Sweeney,
some of which produced little or no public benefit for the Partnership and its affiliated entities
including the Port Authority and the LCRA.
a Substantial and ongoing legal fees and costs for the Partnership's cooperation with the federal
investigation.
Uncalculated substantialcost of staff time to gather data and respond to investigation inquiries.
Direct out-of-pocket costs expected to be incurred as a result of the Missouri State Auditor's
impending audit.

August L,2OL9
Page 2
ln addition to directfinancial losses of the Partnership, the Defendants'conduct has immeasurably injured
the public's trust and perception of the Partnership. Damage to the Partnership's reputation hinders its
effectiveness in accomplishing its mission to attract, retain and facilitate the growth of businesses in the
St. Louis region.
o Since approximately 2Ol7,local and national media outlets have published hundreds of articles
implicating the Partnership in the Defendants'crimes and conduct. Articles have characterized
the Partnership as "beleaguered" and at the center of political battles and the federal
investigation.
o The St. Louis County Council conducted an almost year-long, widely reported ethics investigation
of the Partnership, and withheld Partnership funding until recently.
o lndustry partners and potential Board members have expressed concerns about their own
reputations as a result of association with the Partnership.
o The Partnership had been held in high esteem by the lnternational Economic Development
Council (the "|EDC") as one of only 60 accredited economic development organizations in the
United States. The Defendants'use of the Partnership in public corruption has tainted the
Partnership's reputation within the IEDC and the wider economic development community.
Similarly, the Defendants' conduct interrupted normal Partnership functions and operational capability.
During Sweeney's tenure, from approximately September 30, 2015 to January 3,2019, more than 60% of
the Partnership's staff was replaced. By 2018, under intense public scrutiny and County Council
investigation, Partnership leadership and operations had become dysfunctional.
o Prio r to Ste nger a nd Sweeney's ten u re, the average yea rs of service of Pa rtners hip em ployees was
15 years. Today, five years later, the average years of service of Partnership employees is about 6
years.
o The total number of Partnership employees before Stenger and Sweeney administrations was 68.
Today, the total number of Partnership employees is 54.
The extraordinary loss of human capital and severe reputational damage are compounded by budget
uncertainties, all of which hinder the Partnership's ability to attract and retain talent in the economic
development field. lt is virtually impossible to estimate the time and cost to rebuild the Partnership's
reputation and capabilities.
Finally, there has been a human cost of the Defendants'crimes among current and former Partnership
employees.
a Current employees express shock and anger at the betrayal by Sweeney knowing that she directly
deceived them to carry out directives from Stenger.
a Employees report conflicts with family, and within their personal and professional communities
regarding their association with the Partnership
As described above, the actions of the Defendants severely injured the Partnership and its constituents
financially, operationally, and reputationally. This damage will have lasting impact on the entire St. Louis

August L,2OL9
Page 3
region that the Pannership serves. Notwithstanding the wrongful and illegal actions of the Defendants,
the Partnership is committed to working to restore the trust of the St. Louis community in the Partnership
and to continuing its important mission to foster economic growth throughout the St. Louis region.
Thank you for considering this information.
Sincerely,
The Board of Directorc of the St. Louis Economic Development Partnership

Exhibit 3
ST. LOUIS COUNTY PORT AUTHORITY

7733 FORSYTH BLVD., SUITE 22OO
ST. LOUIS, MO 63105
July 31,2019

St. Louis, MO 53102
United States of America v. Steven V. Stenger, Cause No. 4:19CR312

United States of America v. Sheila A. Sweeney, Cause No. 4:1-9CR375
Dear Judge Perry:
ln accordance with pleas entered by Steven V. Stenger and Sheila A. Sweeney, the defendants in the
above referenced cases (together, the "Defendants"), the St. Louis County Port Authority (the "Port
Authority") is a victim of crimes committed by Defendants. Please accept this letter as a statement on
behalf of the Port Authority under 18 U.S.C. S 3771.
The Port Authority is a political subdivision formed in 1978 under Chapter 58, Revised Statutes of
Missouri. The Port Authority's Board of Commissioners is appointed by St. Louis County, Missouri. The
Port Authority, which is managed by the St. Louis Economic Development Partnership, administers a
budget in excess S5,000,000 annually. At all times covered by the guilty pleas of Defendants, the Port
Authority's Board of Commissioners was appointed by and under the control of Stenger, and Sweeney
acted as Executive Director of the Port Authority.
The corruption scheme the Defendants devised and executed, as described in their guilty pleas, caused
substantial direct financial loss to the Port Authority, including the following:
a A fraudulent contract between the Port Authority and Cardinal Creative Consulting was
executed at the direction of Stenger and Sweeney in the amount of 5130,000, for which the Port
Authority derived no benefit.
a Other contracts that produced little or no benefit were awarded to private parties at the
direction of Stenger and Sweeney outside of normal Port Authority policies and procedures.
While still under investigation, the cost to the Port Authority of such contracts producing little or
no public benefit is as much as and potentially more than 5399,000.
a More than 57,000,000 of unnecessary and ill-conceived grants of Port Authority funds were
awarded to various public and private parties at the direction of Stenger and Sweeney outside of
normal Port Authority policies and procedures; more than 52,000,000 of such grants are being
honored for legal reasons while 55,000,000 of such grants have been cancelled to mitigate the
Port Authority's damages, albeit at substantial reputational cost to the Port Authority.
a Outside consulting, Iegal and audit/accounting contracts and fees to investigate and review Port
Authority operations during the Stenger and Sweeney administrations have been entered into
and incurred, currently in excess of S250,000.

July 31, 2019
Page 2
The impact to the Port Authority's normal operations of Defendant's corruption scheme has also been
significant. As a result of action by the County Council in response to the growing evidence of possible
malfeasance by Stenger and Sweeney, the Port Authority effectively ceased all operations and
expenditures of funds between June 2018 and April 2019, when Stenger resigned as County Executive.
The following are examples of Port Authority operations and legal obligations that were delayed or
impeded during the shutdown:
. The renewal, extension or payment of legitimate community reinvestment grants to other

organizations that relied upon such grants, including grants to Great Streets Natural Bridge
Community Development Corp.; Lemay Housing Partnership; UAW Labor Employment Training
Corp.; The Housing Partnership; NCADA Prevention First; Lemay Child & Family Center; and
Afft on Athletic Association.
o The management of a port authority improvement district and a foreign trade zone within the
port district, as described in Chapter 58, RSMo.
o Consideration of temporary and permanent easement requests for the Metropolitan Sewer
District.
. The purchase and sale of material real estate assets on behalf of St. Louis County and others.
o The redevelopment of the former Jamestown Mall.
o Completion of a major streetscape and stormwater drainage project in Lemay.
o The regular maintenance and management of Port Authority owned property, which has
resulted in numerous code citations and unsafe conditions.
o All other critical economic development activities ordinarily performed by the Port Authority.
The Port Authority has also suffered severe reputational damage as a result of Defendants'corruption
scheme, which will hinder its ability to perform its mission now and in the future. The Port Authority's
ability to effectively operate within St. Louis County and to attract local, state and federalfunding for its
projects is in large part dependent upon its credibility, and Defendants' conduct has immeasurably
injured the public's trust and perception of the Port Authority. Because the Port Authority was central
to the Defendants' schemes, it is impossible to estimate the time, effort and money that will be required
to eliminate the taint of Defendants'crimes and restore its previously outstanding reputation within the
community.
Finally, the Port Authority continues to be directly impacted by the damage done to the St. Louis
Economic Development Partnership, as it has historically relied entirely upon the Partnership for staffing
and leadership. As a result, allof the damage and impacttothe Partnership has resulted in an indirect,
but equally material, impact to the Port Authority. ln late June 2019, the newly appointed Board of
Commissioners commenced a detailed review of the records and operations of the Port Authority during
the approximately 4-year tenures of Stenger and Sweeney. Thus, the Port Authority is engaged in an
ongoing process to determine the impact of the Defendants'crimes on the Port Authority.
We appreciate the opportunity to provide this information for your consideration.
Sincerely,
The Board of Commissioners of the St. Louis County port Authority

Exhibit 4
LAND CIEARANCE FOR REDEVELOPMENT AUTHORITY

7733 FORSYTH BLVD., SUITE 22OO
ST. LOUIS, MO 63105
August 1,,2019

St. Louis, MO 53102
Re United Stotes of Americo v. Steven V. Stenger, Cause No. 4:19CR31-2

United Stotes of Americo v. Sheilo A. Sweeney, Cause No. 4:19CR375
Dear Judge Perry
ln accordance with pleas entered by Steven V. Stenger and Sheila A. Sweeney, the defendants in the above
referenced cases (together, the "Defendants"), the Land Clearance for Redevelopment Authority of the
County of St. Louis (the "LCRA") is a victim of crimes committed by the Defendants. Please accept this
letter as a statement on behalf of the LCRA under 18 U.S.C. S 3771.
The LCRA is a political subdivision formed in 1956 under Land Clearance for Redevelopment Authority
Law, 55 99.300 to 99.650, RSMo. The LCRA's Board of Commissioners is appointed by St. Louis County
and is managed through the St. Louis Economic Development Partnership. The LCRA exists to eradicate
and redevelop blighted and insanitary areas as part of long-term comprehensive planning.
The corruption scheme devised and executed be Defendants, as described in their guilty pleas, caused
substantialdirect financial loss to the LCRA, including the following:
a Fees and costs to review and respond to multiple deficient "development plans" submitted by
Wellston Holdings, LLC for land it acquired through the Defendants' illegal schemes.
a Fees for crisis communications in connection with LCRA denials of Wellston Holdings, LLC's
deficient development plans.
a Undetermined fees and costs of staff in connection with Wellston Holdings, LLC's deficient
development plans.
It is critical for the to recover the land sold to Wellston Holdings, LLC. The LCRA spent over 20 years
LCRA
assembling and performing environmental cleanup on the two parcels of land sold to Wellston Holdings,
LLC. lt's estimated that the LCRA, mostly through federal grants, invested about S10,000,000 in
environmental cleanup costs to make the property suitable for development and marketable.
To recover these parcels, the LCRA's current legal mechanism is exercising a right of repurchase from
Wellston Holdings, LLC, which itself participated in the Defendants' illegal scheme. Repurchasing the
properties will result in additional financial hardship to the LCRA because the LCRA may be required to
borrow all or a portion of the amount needed to fund the repurchase.

August 1,2019
Page 2
Finally, we respectfully suggest that the Court consider the substantial loss to the communities the LCRA
serves. Damage to the LCRA is damage to communities it serves. The LCRA has lost the oppottunity to
consider other development opportunities during Wellston Holdings, LLC's ownership of the properties.
Additionally, the LCRA has been at the center of public controversy in connection with the Defendants'
crimes, causing mistrust and loss of credibility in the communities it serves, such as the City of Wellston.
The Defendants' crimes caused delay and mistrust that will impact the LCRA's ability carry out its long-
term plan to attract investment, expand the City's and County's tax base, and create jobs in the City of
Wellston and surrounding areas.
The Defendants' scheme sought to remove benefits from the community and confer those to private
individuals in exchange for direct gain to the Defendants and others. Their illegal scheme has in fact
delayed, and will continue to hinder, development in communities with the most need. The human impact
and cost of this is virtually incalculable.
Sincerely,
The Board of Commissioners

of the Land Clearance for Redevelopment Authority of the County of St. Louis

Defendant Steve Stenger Sentencing Memorandum

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Defendant Steve Stenger Sentencing Memorandum

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Case: 4:19-cr-00312-CDP Doc.

#: 43 Filed: 08/02/19 Page: 1 of 12 PageID #: 208

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA, )

1. By any standard or measure, defendant Steven Stenger’s criminal conduct calls

and political subdivision in Missouri, with approximately 1,000,000 residents. In comparison,

Economic Development Partnership to extend a lobbying contract to one of defendant’s

contract or grant, and that he continue to personally win politically.

Louis Economic Development Partnership. Defendant recommended Sheila Sweeney be

budgets his various non-merit hires were being paid from:

“That’s one of the greatest powers I have. That I have 52 people

Defendant’s pay to play scheme in which he collected hundreds of thousands of dollars

history and characteristics of defendant, 18 U.S.C. 3553(a)(1). As to defendant’s history and

staff in a private conversation on November 7, 2018, following the general election:

STENGER: “How ‘bout that motherf---ers? I don’t show up to the

County required an Amendment to the Missouri State Constitution, anticipated to be put to

Missouri voters during 2020.

a major donor to Stenger’s 2018 re-election campaign, contributing approximately $700,000

discussed in a private conversation with his executive staff on October 9, 2018.

STENGER: “And in my second term I really don’t want to do

personally benefit from his own relationship with Better Together.

of sends a message to all of them that I trust them. And they’ve

in a November 8, 2018 private conversation:

STENGER: “We’re pretty solid with leadership, with me being the

STENGER: “I could give a f--- about 2020. I’m in the amendment.

In further considering defendant’s history and characteristics, throughout his tenure as

of his executive staff on January 2, 2019:

STENGER: “This jackoff [County Counselor] does not understand

STENGER: “We’re not going to advance our bill if [Contractor] is

members of his executive staff on October 19, 2018.

STENGER: “I’m going to meet with the head of [Page’s Employing

case will have that desired deterrent effect.

consider these collateral consequences in framing a more lenient sentence, it would be

tantamount to favoring criminals with privileged backgrounds.

deserve it, and fairness and justice require it.

offenses as is required by 18 U.S.C. 3553(a)(2)(A). As President Roosevelt said:

There can be no crime more serious than bribery. Other offenses

law. Under our form of Government all authority is vested in the

and should be justly punished.

/s/ Hal Goldsmith

ST" L UIS COUNTY

July 24, zotg

Honorable Catherine D. Perry

R:e: United States u. SteuenV. Stenger, Case No. 4:t9CR3rz CDP/NCC

As elected representatives of St. Louis County government, we are jointly writing

The defendant con the good of St. Louis County.

ADMINISTRATION BUILDING . 4 I S, CENTRAL AI/EMIE . CLAWON, MISSOUN 6 3 I 05

Hon. Catherine D. Perry

The defendant's criminal enterprise put dedicated public employees in difficult if

Hon. Catherine D. Perry

_ Similarly, the defendant's dismissal of decisions regarding the county's day-to-

Hon. Catherine D. Perry

The defendant's systemic "pay-to-play" scheme also severely compromised St.

Hon. Catherine D. Perry

In the final analysis, the defendant never behaved as if he appreciated or even

Walton Gray Harder

The Honorable Catherine D. Perry

Re: lJnited Stotes of Americo v. Steven V. Stenger, Cause No. 4:19CR312

Dear Judge Perry:

The Honorable Catherine D. Perry

The Honorable Catherine D. Perry

Thank you for considering this information.

The Board of Directorc of the St. Louis Economic Development Partnership

ST. LOUIS COUNTY PORT AUTHORITY