ERIC ADAMS, ANSWER TO THE INDICTMENT and

ANSWER TO THE INDICTMENT AND AFFIRMATIVE DEFENSES
Defendant, ERIC ADAMS, by and through his counsel, respectfully submits this Answer and Affirmative Defenses to the Indictment filed by the United States of America. For his defense, Mr. Adams states as follows:
The defendant, Eric Adams, denies all allegations of wrongdoing made by the United States government and asserts that the charges are baseless, relying on circumstantial evidence and misinterpretations of routine political and personal interactions. Mr. Adams has always maintained his integrity as an elected public official and as Mayor of New York City. At no time did Mr. Adams knowingly engage in unlawful conduct, solicit illegal contributions, or use his office for personal enrichment.

1. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
UNITED STATES DISTRICT COURT  SOUTHERN DISTRICT OF NEW YORK
UNITED
STATES OF AMERICA,
Plaintiff,
vs.
ERIC
ADAMS,
Defendant
Case
No.
:

24
CRIM 556
ANSWER
TO THE INDICTMENT AND
AFFIRMATIVE
DEFENSES
ANSWER
TO THE INDICTMENT AND AFFIRMATIVE DEFENSES
Defendant,
ERIC ADAMS, by and through his counsel, respectfully submits this Answer and Affirmative Defenses
to
the Indictment filed by the United States of America. For his defense, Mr. Adams states as follows:
The
defendant, Eric Adams, denies all allegations of wrongdoing made by the United States government and asserts
that
the charges are baseless, relying on circumstantial evidence and misinterpretations of routine political and
personal
interactions. Mr. Adams has always maintained his integrity as an elected public official and as Mayor of
New
York City. At no time did Mr. Adams knowingly engage in unlawful conduct, solicit illegal contributions, or
use
his office for personal enrichment.
GENERAL
DENIAL
Except
where explicitly admitted, Defendant denies each and every allegation, inference, and conclusion in the
indictment.
SPECIFIC
DEFENSES AND RESPONSES
ANSWER
TO THE INDICTMENT AND AFFIRMATIVE DEFENSES

-
1

2. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1.Campaign
Contributions:
Good
Faith Compliance: Mr. Adams and his campaign team took diligent steps to comply with all federal and
local
campaign finance laws. Any errors in campaign finance reports were unintentional clerical oversights
rather
than deliberate acts of fraud. These reporting mistakes, if they occurred, were promptly corrected upon
discovery.
No
Knowledge of Straw Donations: The defendant denies knowledge of any alleged straw donations. Mr. Adams
relied
on his campaign finance team to ensure that all donations were legal and compliant with the regulations. He
never
encouraged or solicited donations from foreign nationals or through illegal means. If straw donations were
made,
they were without Mr. Adams' knowledge or consent.
2.
Foreign Contributions and Influence:
Lack
of Direct Involvement: Any interaction with foreign nationals or governments was carried out in a diplomatic
capacity
as an elected official, aimed at promoting international relations and economic development for New York
City.
There was no quid pro quo agreement, and any contributions made were done legally and without Mr. Adams'
solicitation
or improper influence.
Travel
and Benefits: The defendant asserts that any travel or benefits he received were disclosed to the appropriate
regulatory
bodies when required, and any failure to do so was a misunderstanding of disclosure obligations, not an
intentional
act to deceive the public or authorities. Some travel was related to his duties as an elected official and
offered
by organizations with no expectation of political favors.
3.
Matching Funds Program:
ANSWER
TO THE INDICTMENT AND AFFIRMATIVE DEFENSES

-
2

3. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Unintentional
Misreporting: If any improper matching funds were received by Mr. Adams' campaign, they were not
intentionally
solicited. The matching fund process is complicated and involved third-party handling, and any errors
were
administrative rather than fraudulent.
No
Material Misrepresentation: The defendant denies that any certification made in support of matching funds was
fraudulent.
Mr. Adams relied on his campaign staff and consultants to ensure compliance with all legal
requirements.
4.
FDNY and Turkish Consulate Issue:
No
Improper Influence: Mr. Adams denies that he applied any improper pressure on FDNY to obtain a certificate of
occupancy
for the Turkish Consulate building. Any communications he had with city departments were routine
inquiries
in his capacity as Brooklyn Borough President and later as Mayor, intended to facilitate government
operations
efficiently. These actions were not in exchange for personal gain, and the building’s compliance with
safety
standards was not compromised by Mr. Adams' involvement.
Lack
of Corrupt Intent: The defendant maintains that he never took any official actions with the intent to receive
personal
benefits. Any alleged communication between Mr. Adams and Turkish officials was purely diplomatic and
in
the best interest of New York City, rather than part of any corrupt arrangement.
5.
Deletion of Messages:
No
Malicious Intent: Mr. Adams denies the allegation that he purposefully deleted messages to conceal evidence of
wrongdoing.
As a public figure, he communicated with many individuals on a daily basis and followed routine
practices
in managing communications. Any deleted messages were routine and had no bearing on the accusations in
this
indictment.
ANSWER
TO THE INDICTMENT AND AFFIRMATIVE DEFENSES

-
3

4. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
6.
Other Improper Benefits Allegations:
No
Illegal Acceptance: Mr. Adams denies accepting illegal benefits in the form of discounted travel, hotel
accommodations,
or other personal favors. Where benefits were accepted, they were offered without the expectation
of
reciprocal political favors, and all necessary steps were taken to comply with disclosure requirements.
AFFIRMATIVE
DEFENSES
1.
Lack of Specific Intent:

The government has failed to establish that Mr. Adams acted with the specific intent to violate the law. All of Mr.
Adams’
actions were undertaken in good faith and in the honest belief that they were in compliance with the law.
2.
Due Process Violations:
The
government’s indictment is based on speculative and circumstantial evidence, and its investigation may have
violated
Mr. Adams’ constitutional rights under the Fourth and Fifth Amendments, particularly with respect to
privacy
and procedural fairness. Any evidence obtained through unconstitutional means must be excluded.
3.Selective
Prosecution:
Mr.
Adams is being unfairly targeted due to his prominence as the Mayor of New York City, and his political
connections.
This selective prosecution undermines the fairness of the legal process, and Mr. Adams requests a
thorough
review of prosecutorial motivations.
4.First
Amendment Protections:
ANSWER
TO THE INDICTMENT AND AFFIRMATIVE DEFENSES

-
4

5. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
The
actions Mr. Adams took in his official capacity as an elected official are protected by the First Amendment.
Engaging
with foreign officials and donors, promoting his political platform, and raising campaign funds are all
constitutionally
protected activities.
PRAYER
FOR RELIEF
Wherefore,
Defendant Eric Adams respectfully requests the following relief:
1.
That the Court dismiss the indictment with prejudice.
2.
That the Court suppress any evidence obtained in violation of Mr. Adams' constitutional rights.
3.
That the Court award any other relief that it deems just and proper.
DATED:
September 26, 2024
Respectfully
Submitted,
/s/
Counsel for Defendant Eric Adams
(GenAI
Law Firm
)
ANSWER
TO THE INDICTMENT AND AFFIRMATIVE DEFENSES

-
5