UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

JUDGE GETTLEMAN
MAGISTRATE JUDGE DENLOW

UNITED STATES OF AMERICA . 99CR325

Violations: Title 18,

ANTHONY T. CENTRACCHIO, United States Code,

THOMAS R. TUCKER, Sections 2, 922 (g) , 1511,

ROBERT S. URBINATI, and 1251, 1955, and 1962 (d)

ROBERT D . NATALE

COUNT ONE

The SPECIAL JANUARY 1999-1 GRAND JURY charges:

I. THE ENTERPRISE

1. At all times material to this indictment, Louis "the Mooch" Eboli, ANTHONY T. CENTRACCHIO, and THOMAS R. TUCKER, were members and associates of an "enterprise" as that term is defined in Title 18, United States Code, Section 1961(4), that is, a group of individuals associated in fact, which enterprise was engaged in and the activities of which affected interstate commerce. This enterprise, consisting of the aforementioned individuals and others, is hereby referred to for purposes of this count as the "Eboli-Centracchio Enterprise." The Eboli-Centracchio Enterprise was part of a larger criminal organization known to the public as "the mob," and to its members and associates as "The Outfit."

2. Defendants ROBERT S. URBINATI and ROBERT D. NATALE were employed by and associated with the Eboli-Centracchio Enterprise.

3. The Eboli-Centracchio Enterprise existed primarily to provide income to its members and associates through illegal activities. The illegal activities of the enterprise included: conducting, and aiding and abetting the conduct of, illegal gambling operations, including a video gambling machine business; making, soliciting, and receiving bribes for the protection of, and assistance in, the operation of illegal gambling operations and other interests, including adult entertainment businesses, in Franklin Park, Melrose Park, Northlake, Stone Park, and elsewhere in the State of Illinois; and collecting "street tax," that is, extortion payments required as a cost of operating various businesses including the operation of adult entertainment businesses.

4. In order to carry out its activities, the Eboli-Centracchio Enterprise maintained a structure and chain of command, which consisted of a leader or "boss, 11 agents, and associates, all of whom were compensated from its activities:

a. Louis "the Mooch" Eboli was the leader or boss of the Eboli-Centracchio Enterprise until his death on about September 26, 1987. In this capacity, he supervised the (1) collection of money including the payment of "street tax," and (2) distribution of sums of money for the payment of bribes to law enforcement and public officials in Franklin Park and Stone Park, Illinois, for the protection of the operation of illegal gambling activities and assistance in the conduct of adult entertainment businesses.

b. Defendant ANTHONY T. CENTRACCHIO became the leader or boss of the Eboli-Centracchio Enterprise sometime subsequent to the death of Louis "the Mooch" Eboli. In this capacity, as had Louis "the Mooch" Eboli, he supervised the (1) collection of money including the payment of "street tax," and (2) distribution of sums of money for the payment of bribes to law enforcement and public officials in Franklin Park, Melrose Park, Northlake, Stone Park, and elsewhere in the State of Illinois, for the protection of the operation of video gambling machines and assistance in the conduct of adult entertainment businesses in those areas.

c. Defendant THOMAS R. TUCKER, also known as "Tommy,' was the second-in-command of the Eboli-Centracchio Enterprise. TUCKER was a former lieutenant with the Village of Stone Park (Illinois) Police Department. TUCKER relayed orders and messages from ANTHONY T. CENTRACCHIO to members and associates of the Eboli-Centracchio Enterprise, and distributed money from ANTHONY T. CENTRACCHIO and Louis "the Mooch" Eboli to members and associates of the Eboli-Centracchio Enterprise.

d. Defendant ROBERT S. URBINATI, also known as "Bobby," was employed as a police officer by the Village of Franklin Park (Illinois) Police Department between approximately 1968 and 1995. URBINATI received cash bribe payments from TUCKER on an approximately monthly basis for the purpose of URBINATI's protection of the operation of video gambling machines in Franklin Park, Illinois.

e. Defendant ROBERT D. NATALE, was employed as a police officer by the Village of Stone Park (Illinois) Police Department between approximately 1971 and 1989. Between approximately 1984 and April 24, 1989, he served as the Stone Park Deputy Chief of Police. Between approximately April 24, 1989 and the time of this indictment, he served as the Mayor of Stone Park, Illinois. NATALE received cash bribe payments from TUCKER on an approximately monthly basis for the purpose of NATALE's protection of the operation of video gambling machines in Stone Park, Illinois, and assistance in the establishment and operation of adult entertainment businesses.

f. Seymour Sapoznik was employed by the Village of Stone Park (Illinois) Police Department from about 1966 to 1990. He was a police lieutenant from 1976 to 1984, and the Chief of Police from 1984 to about November of 1990. On about November 4, 1990, Sapoznik resigned as Stone Park Chief of Police in order to take the job of Chief of Police in the Village of Northlake, Illinois. Sapoznik was the Northlake Chief of Police through December of 1994. Sapoznik received cash bribe payments from TUCKER on an approximately monthly basis for the purpose of his protection of the operation of video gambling machines, first in Stone Park and then in Northlake, Illinois.

II. THE RACKETEERING CONSPIRACY

7. Beginning in or about 1978, the exact date being to the Grand Jury unknown, and continuing thereafter up to and including

about February of 1999, in the Northern District of Illinois, Eastern Division, and elsewhere,

ANTHONY T. CENTRACCHIO,

THOMAS R. TUCKER,

ROBERT S. URBINATI, and

ROBERT D. NATALE,

defendants herein, along with persons both known and unknown to the Grand Jury, including, but not limited to, Robert T. Cechini, Nicholas J. Ciotti, Rocco R. Circelli, Lawrence Scialabba, Louis "the Mooch" Eboli, and Seymour Sapoznik and other law enforcement officers, being persons employed by and associated with the Eboli-Centracchio Enterprise, which enterprise engaged in and the activities of which affected interstate commerce, conspired to violate Title 18, United States Code, Section 1962(c), that is, to conduct and participate, directly and indirectly, in the conduct of the affairs of the enterprise through a pattern of racketeering activity, consisting of multiple acts involving violations chargeable under the following laws of the State of Illinois and multiple acts indictable under the following laws of the United States:

a. 18 U.S.C. H 1955 and 2 (relating to the prohibition of illegal gambling businesses);

b. Illinois Revised Statutes, Chapter 38, Sections 8-2 and 33-1 (which later became 720 ILCS 5/8-2 and 331) (an act involving bribery);

c. Illinois Revised Statutes, Chapter 38, Sections 8-2 and 33-3 (which later became 720 ILCS 5/8-2 and 333) (an act involving bribery);

d. 18 U.S.C. § 1511 (relating to the obstruction of State or local law enforcement); and

e. 18 U.S.C. § 1951 (relating to interference with commerce by robbery or extortion).

8. It was a part of the conspiracy that the defendants agreed that at least two acts of racketeering would be committed by a conspirator in the conduct of the affairs of the enterprise.

III. PURPOSE, METHOD, AND MEANS OF THE CONSPIRACY

9. The form and substance of the conspiracy was as follows:

a. The Operation of an Illegal Gambling Business

It was further a part of the conspiracy that defendants ANTHONY T. CENTRACCHIO, THOMAS R. TUCKER, ROBERT S. URBINATI, ROBERT D. NATALE, and co-conspirators Robert T. Cechini, Nicholas J. Ciotti, Rocco R. Circelli, Lawrence Scialabba, and Seymour Sapoznik and other law enforcement officers, and others, known and unknown to the grand jury, conducted illegal gambling through the use of video gambling machines and devices. Co-conspirators Cechini, Ciotti, Circelli, and Scialabba conducted the gambling business by operating video gambling machine companies under names including OK Amusement and All Games Amusement, and through these companies distributing video gambling machines to bars and restaurants in communities including, but not limited to, Stone Park, Melrose Park, Northlake, and Franklin Park, Illinois. Coconspirators CENTRACCHIO, TUCKER, URBINATI, and NATALE conducted the gambling business through the payment and receipt of bribes to

law enforcement and public officials in order to protect the operation of the gambling business.

(1) To activate these video gambling machines and devices, which included, but were not limited to, games known as "Cherry Master," "Bingo," "Joker Poker," and "Magical Odds," players had to insert coins or currency into the coin or paper money receptacles.

(2) Some of these machines and devices dealt images such as five playing cards, simulating the card game called "draw poker." Players earned rewards based upon the rank of the resulting poker hand. Pay-outs to winning players were based on the total of points accumulated. These video gambling machines and devices could be adjusted by the co-conspirators to either raise or lower the amount of winning pay-outs.

(3) Another kind of video gambling machine and device was similar to a slot machine. To activate these machines and devices, players had to insert the money into the coin or paper money receptacles on the machines and devices. The players then pulled a handle or pressed a button to spin the mechanical reels or electronic facsimiles of reels that had various symbols. The players won when the symbols on the reels appeared in a certain number or order.

(4) Typical "slot" machines and devices used electronic systems that guaranteed that the operator retained a portion (percentage) of the wagers as profits. From a player's standpoint, the operation of the machine and device was essentially

random. As such, players had no control over what combination of symbols would appear, and no element of skill was involved in the game. Players received immediate notice of the amount they had won or lost, and the reward schedules were imprinted on the glass screens on the machines and devices.

(5) The machines and devices electronically accumulated "credits," and players were paid based upon the number of accumulated credits. After a winning player had been paid, the video gambling machines and devices had a "knock off" device (normally a button or combination of buttons) that could be pushed to clear the accumulated credits. Also, the video gambling machines and devices had separate electronic counters inside the machines and devices that recorded both the total number of plays on the machine, and the total of winning credits won on and cleared off the machines and devices.

(6) Certain co-conspirators placed and caused the placement of these video gambling machines and devices at various locations, such as taverns, fraternal clubs, and restaurants in Franklin Park, Melrose Park, Northlake, Stone Park, and elsewhere, in the State of Illinois, and co-conspirator owners, managers and representatives of the taverns, fraternal clubs, and restaurants accepted placement of these gambling machines and devices in return for a portion of the profits from the machines and devices.

(7) Certain co-conspirators instructed and caused the instruction of owners, managers and representatives of the taverns, fraternal clubs, and restaurants, at which the video

gambling machines and devices were placed, on such topics as how to set up the machines and devices; how to properly pay off the winners on the machines and devices; how to "clear" or "knock off" the accumulated credits from the machines and devices after the player had been paid off; and other topics necessary to the maintenance of the illegal gambling business.

(8) Certain co-conspirators entered into agreements regarding the operation of the video gambling machines and devices. These agreements included, but were not limited to, agreements regarding the distribution of the proceeds from the video gambling machines and devices.

(9) Certain co-conspirators, including Louis "the Mooch" Eboli, told certain owners, managers and representatives of the taverns and restaurants, at which the video gambling machines and devices were placed, that a portion of the proceeds from the video gambling machines and devices were used to bribe public and law enforcement officials to allow the unhindered illegal operation of the video gambling machines and devices.

(10) Certain co-conspirators told owners, managers and representatives of the taverns and restaurants at which the video gambling machines and devices were placed, that if they or employees of establishments were arrested for conducting illegal gambling on the video gambling machines, that attorneys would be provided for their representation at no cost to those arrested.

(11) When law enforcement officers who did not receive bribes arrested owners, managers and representatives of the

taverns and restaurants at which the video gambling machines and devices were placed, certain co-conspirators arranged and paid for their representation on the criminal charges by attorneys chosen by co-conspirators.

(12) Certain co-conspirators would and did visit the taverns, fraternal clubs, and restaurants, in which the video gambling machines and devices were placed on a regular basis (normally weekly), to collect proceeds from the machines. During these regular visits, co-conspirators would and did determine the amount of money played on the machines (known as the "ins), and the amount of money paid to winning customers on the machines (known as the "outs"). The collector would and did open the machines and devices and read the electronic counters inside the machines that recorded both the total number of plays on the machines and the total number of winning credits won, and clear off the machines since the last collection in order to determine the amount of profit on the machines. The collector would and did then confer with the representative of each location and review the accounting. Owners, managers and representatives of the taverns, fraternal clubs, and restaurants were credited for the amount of money paid to winning customers (the "outs"), and the resulting cash proceeds from the machines were split between the collectors and the owners, managers and representatives of the taverns, fraternal clubs, and restaurants.

(13) Certain co-conspirators would and did warn the owners, managers and representatives of the taverns, fraternal

clubs, and restaurants to be careful to whom they paid money on the video gambling machines and devices because of possible law enforcement investigations. In particular, they warned the owners, managers and representatives to only pay money to winning customers whom they knew well, and to beware of law enforcement efforts. Those customers who were not known were to be told that the video gambling machines were for amusement only.

(14) Certain co-conspirators, including Louis "the Mooch" Eboli, and defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER, made monthly bribe payments to certain public and law enforcement officials including defendants ROBERT S. URBINATI and ROBERT D. NATALE, and Seymour Sapoznik and other law enforcement officers, to assure the unhindered illegal operation of the video gambling machines and devices.

b. State Bribery

It was further a part of the conspiracy that to protect the operation of these video gambling machines, certain coconspirators, including ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER, defendants herein, promised and tendered cash payments to other co-conspirators, including ROBERT S. URBINATI and ROBERT D. NATALE, defendants herein, and co-conspirators Seymour Sapoznik and other law enforcement officers, who were public officers and employees, to influence them not to enforce laws relating to the operation of video gambling machines and to assist them in the establishment and operation of adult entertainment businesses.

Some of these cash payments were made monthly, normally within the first few days of each month.

c. State Bribery (Official Misconduct)

It was further a part of the conspiracy that certain coconspirators who were public officers and employees, including ROBERT S. URBINATI and ROBERT D. NATALE, defendants herein, and coconspirators Seymour Sapoznik and other law enforcement officers, received, retained, and agreed to receive cash payments from certain co-conspirators, including ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER, knowing that the payment of this cash was for the purpose of influencing them not to enforce laws relating to the operation of video gambling machines. These cash payments were received monthly, normally within the first few days of each month.

d. Obstructing State and Local Law Enforcement

It was further a part, of the conspiracy that, as set forth more fully in Count Three, ANTHONY T. CENTRACCHIO, THOMAS R. TUCKER, ROBERT S. URBINATI, and ROBERT D. NATALE, defendants herein, and co-conspirators Seymour Sapoznik and other law enforcement officers, and others, known and unknown to the Grand Jury; conspired to obstruct the enforcement of the criminal laws of the State of Illinois and political subdivision thereof, in particular, Illinois Revised Statutes, Chapter 38, Sections 8-2, 28-1, and 28-3, with the intent to facilitate an illegal gambling business; one or more of such persons (1) having done an act to effect the object of such conspiracy; (2) being an official and employee, elected, and appointed, of the State of Illinois and

political subdivision; and (3) having conducted, financed, managed, supervised, directed, or owned all or part of an illegal gambling business.

e. Extortion

It was further a part of the conspiracy that to generate income, defendant ANTHONY T. CENTRACCHIO and co-conspirator Louis "the Mooch" Eboli committed and attempted to commit extortion, which would and did affect commerce, by collecting and attempting to collect property, namely money, in the form of "street tax" from adult entertainment businesses, the consent of the owners and operators of these adult entertainment businesses having been induced by the wrongful use of actual and threatened force, violence, and fear. Such collection of "street tax" included, but was not limited to, collections from such businesses as the Galaxy Bookstore, Stone Park, Illinois; Crossroads Bookstore, Bristol, Wisconsin; Odyssey Bookstore and Satellite News and Video, Bristol, Wisconsin; Ogden Bookstore, Downers Grove, Illinois; the Admiral Theater, Chicago, Illinois; and other adult entertainment businesses.

10. It was further a part of the conspiracy that the conspirators would and did misrepresent, conceal and hide, and cause to be misrepresented, concealed, and hidden the purposes of, and acts done in furtherance of, the conspiracy.

All in violation of Title 18, United States Code, Section 1962 (d) .

COUNT TWO

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

From in or about 1980 and continuing through at least December of 1994, in the Northern District of Illinois, Eastern Division, and elsewhere,

ANTHONY T. CENTRACCHIO,

THOMAS R. TUCKER,

ROBERT S. URBINATI, and

ROBERT D. NATALE,

defendants herein, together with Robert T. Cechini, Nicholas J. Ciotti, Rocco R. Circelli, and Lawrence Scialabba, and other persons known and unknown to the Grand Jury, knowingly conducted all or part of an illegal gambling business, that is, a business involving the use of video gambling machines and devices in the western Chicago suburbs and surrounding areas, which business was in substantially continuous operation for a period in excess of thirty (30) days, which involved five or more persons who conducted, financed, managed, supervised, directed, and owned all or part of the business, and which was a violation of the following laws of the State of Illinois: Illinois Revised Statutes, Chapter 38, Sections 8-2, 28-1(a)(1), (3), and (5) and 28-3, which later became 720 ILCS 5/8-2, 5/28-1(1), (3), and (5), and 5/28-3.

In violation of Title 18, United States Code, Sections 1955 and 2.

COUNT THREE

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

1. From in or about 1978 and continuing through at least December of 1994, in the Northern District of Illinois, Eastern Division, and elsewhere,

ANTHONY T. CENTRACCHIO,

THOMAS R. TUCKER,

ROBERT S. URBINATI, and

ROBERT D. NATALE,

defendants herein, conspired together and with Seymour Sapoznik and other law enforcement officers, and others known and unknown to the Grand Jury, to obstruct the enforcement of the criminal laws of the State of Illinois, that is Illinois Revised Statutes, Chapter 38, Sections 8-2, 28-1 and 28-3 (effective January 1, 1993, the designation of these sections was changed to 720 ILCS §§ 5/8-2, 5/28-1, and 5/28-3), with intent to facilitate an illegal gambling business.

2. At all times during the course of the conspiracy, defendant ROBERT S. URBINATI was an official and employee of the village of Franklin Park, Illinois, that is, a police officer, and defendant ROBERT D. NATALE was an official and employee of the Village of Stone Park, Illinois, that is, a police officer and then the mayor.

3. Between in or about 1980 and November of 1990, Seymour

Sapoznik was an official and employee of the Village of Stone Park, Illinois, that is, a police officer, and between in or about November of 1990 and December of 1994, he was an official and

employee of the Village of Northlake, Illinois, that is, a police officer.

4. At all times during the course of the conspiracy, one or more of the co-conspirators conducted all or part of an illegal gambling business, which business included the maintenance and operation of video gambling machines, all in violation of the aforesaid laws of the State of Illinois.

5. At all times during the course of the conspiracy, the said illegal gambling business involved five or more persons who conducted financed, managed, supervised, directed, and owned all or part of said business and said business remained in substantially continuous operation for a period in excess of thirty days.

OVERT ACTS

6. In furtherance of said conspiracy and to effect the object thereof, the defendants and their co-conspirators did the following acts among others:

a. On or about October 2, 1992, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met at the Paddlewheel Restaurant, River Forest, Illinois.

b. On or about December 2, 1992, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met in the parking lot of the Paddlewheel Restaurant, River Forest, Illinois.

c. On or about January 5, 1993, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met in the parking lot of the Paddlewheel Restaurant, River Forest, Illinois.

d. On or about February 2, 1993, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met in the parking lot of the Paddlewheel Restaurant, River Forest, Illinois. After this meeting, defendant TUCKER counted a quantity of United States Currency. Later that same day, defendant TUCKER met with defendant ROBERT S. URBINATI and also drove to and entered the Stone Park Police Station.

e. On or about March 2, 1993, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met in the parking lot of the Paddlewheel Restaurant, River Forest, Illinois. At this meeting defendant CENTRACCHIO handed defendant TUCKER an envelope that defendant TUCKER put inside his coat. Later that same day, defendant TUCKER drove to and entered the Stone Park Police Station. Defendant TUCKER subsequently drove to the Northlake Municipal Building where he picked up Seymour Sapoznik.

f. On or about April 2, 1993, defendant THOMAS R. TUCKER drove to and entered A.C.T. Medical Center, an established owned and operated by defendant ANTHONY T. CENTRACCHIO. Later that same day, defendant TUCKER drove to the Stone Park Police Department and then drove to the Northlake Municipal Building parking lot where he placed a telephone call to the office of Seymour Sapoznik.

g. On or about May 3, 1993, defendant THOMAS R. TUCKER drove to and entered A.C.T. Medical Center.

h On or about June 2 , 1993, defendant THOMAS R . TUCKER drove to and entered A.C.T. Medical Center.

i. On or about July 2, 1993, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met at the Paddlewheel Restaurant, River Forest, Illinois. When defendant TUCKER left the meeting with defendant CENTRACCHIO, he had in his pocket a white envelope. Thereafter, defendant TUCKER met with Seymour Sapoznik.

j. On or about August 3, 1993, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met at the Paddlewheel Restaurant, River Forest, Illinois.

k. On or about September 2, 1993, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met at the parking lot of the Paddlewheel Restaurant, River Forest, Illinois. During this meeting defendant CENTRACCHIO passed defendant TUCKER an envelope. Defendant TUCKER subsequently went to Grandma Sally's Restaurant, Stone Park, Illinois, and met with individuals including defendant ROBERT S. URBINATI and a Melrose Park law enforcement officer. Later, that same day, defendant TUCKER drove to the Stone Park Police Department where a Stone Park law enforcement officer entered defendant TUCKER's car.

1. On or about November 2, 1993, defendant THOMAS R. TUCKER drove to and entered Riviera Carpets. Shortly after defendant TUCKER left Riviera Carpets, defendant ANTHONY T. CENTRACCHIO also left. After leaving Riviera Carpets, defendant TUCKER met with defendant ROBERT S. URBINATI and a co-conspirator.

m. On or about December 2, 1993, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met outside Floors and Walls Unlimited, 9606 Franklin Avenue, Franklin Park, Illinois.

Defendant TUCKER subsequently met with a Melrose Park law enforcement officer at Grandma Sally's Restaurant, Stone Park, Illinois. Later that same day, defendant CENTRACCHIO met with defendant ROBERT S. URBINATI outside the Paddlewheel Restaurant, River Forest, Illinois, and handed defendant URBINATI a white envelope.

n. On or about January 5, 1994, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met at the Paddlewheel Restaurant, River Forest, Illinois, and defendant TUCKER placed an envelope in his pocket. Defendants TUCKER and CENTRACCHIO were subsequently joined by defendant ROBERT S. URBINATI. Defendants TUCKER and URBINATI subsequently left the Paddlewheel Restaurant and drove to Grandma Sally's Restaurant, Stone Park, Illinois, where they entered and met with a Melrose Park law enforcement officer.

o. On or about February 2, 1994, defendant THOMAS R. TUCKER drove to and entered A.C.T. Medical Center, Chicago, Illinois. Later that same day, defendant TUCKER met with defendant ROBERT S. URBINATI and a Melrose Park law enforcement officer.

p. On or about March 2, 1994, defendant ANTHONY T. CENTRACCHIO collected a street tax payment of United States Currency from Individual A at Riviera Carpets.

q. On or about March 3, 1994, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met in the parking lot of the Paddlewheel Restaurant, River Forest, Illinois, and defendant CENTRACCHIO handed defendant TUCKER an envelope. Defendants

CENTRACCHIO, TUCKER, and ROBERT S. URBINATI then met inside the Paddlewheel Restaurant.

r. On or about March 3, 1994, defendant ANTHONY T. CENTRACCHIO collected a street tax payment of United States Currency from Individual B at A.C.T. Medical Center.

s. On or about March 5, 1994, defendant ANTHONY T. CENTRACCHIO had a conversation with Individual B during which he showed the individual a piece of paper and explained the figures thereon to the individual.

t. On or about April 1, 1994, defendants THOMAS R. TUCKER and ROBERT S . URBINATI met inside defendant TUCKER' s car and TUCKER and defendant URBINATI had a conversation about the $500 a month defendant ROBERT D. NATALE was getting for not bothering the machines. Defendant TUCKER told defendant URBINATI that if he (TUCKER) was mayor, they would not get him so cheap. Defendant TUCKER further told defendant URBINATI how he would split the proceeds from the video gambling machines if he were the mayor.

u. On or about April 2, 1994, defendants THOMAS R. TUCKER and ROBERT S. URBINATI met and had a discussion regarding defendant ROBERT D. NATALE receiving $500 a month for the machines and defendant ANTHONY T. CENTRACCHIO having given defendant TUCKER $5,000 to give to defendant NATALE when an adult entertainment business in Stone Park, Illinois opened.

v. On or about April 2, 1994, defendants ANTHONY T. CENTRACCHIO, THOMAS R. TUCKER, and ROBERT S. URBINATI met at A.C.T. Medical Center, Chicago, Illinois, and defendant CENTRACCHIO tossed

defendant URBINATI a white envelope. After leaving A.C.T. Medical Center, defendants TUCKER AND URBINATI had a conversation about the "24" that should be there, and defendant TUCKER said that defendant CENTRACCHIO never makes a mistake except "one time he made a mistake the other way" but defendant TUCKER said he caught defendant CENTRACCHIO. Defendant URBINATI also asked defendant TUCKER whether defendant TUCKER wanted defendant URBINATI to take 775. Defendant TUCKER also asked defendant URBINATI whether defendant URBINATI had "change for some C-notes?"

w. On or about April 5, 1994, defendants THOMAS R. TUCKER and Seymour Sapoznik met inside defendant TUCKER's car in front of the Northlake Police Department.

x. On or about May 3, 1994, defendant ANTHONY T. CENTRACCHIO collected a street tax payment of United States Currency from Individual B at A.C.T. Medical Center.

y. On or about May 4, 1994, defendants ANTHONY T. CENTRACCHIO, THOMAS R. TUCKER, and ROBERT D. NATALE met at Kappy's Restaurant, Villa Park, Illinois. Soon thereafter, that same day, defendant TUCKER counted a quantity of United States Currency and met with defendant ROBERT S. URBINATI at the parking lot of Grandma Sally's, Stone Park, Illinois. Later that same day, defendant TUCKER met with a Stone Park law enforcement officer.

z. On or about May 5, 1994, defendant THOMAS R. TUCKER and Seymour Sapoznik met in defendant TUCKER's car parked behind the Northlake Municipal Building.

aa. On or about May 12, 1994, defendant ANTHONY T. CENTRACCHIO possessed the piece of paper he had shown to Individual B on March 5, 1994 (see paragraph "s" above). This piece of paper listed the figure "10175" as well as the initials"R,11 1' FP," "NL," "CL," "SP," and "M" with numbers written next to the initials.

bb. On or about May 2 0 , 19 94 , defendant THOMAS R . TUCKER had a telephone conversation with a Stone Park law enforcement officer regarding an adult entertainment business.

cc On or about July 6, 1994, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met in the parking lot of Dapper's Restaurant, River Grove, Illinois. Later that same day, defendant TUCKER met with ROBERT S. URBINATI and Seymour Sapoznik.

dd. On or about August 3, 1994, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met at the Paddlewheel Restaurant, River Forest, Illinois, and after leaving his meeting with defendant CENTRACCHIO, TUCKER counted a quantity of United States currency. After leaving the meeting, defendant TUCKER drove to the Stone Park Police Department. Defendant TUCKER subsequently called Seymour Sapoznik and arranged a meeting the next day.

ee. On or about August 4, 1994, defendant THOMAS R. TUCKER and Seymour Sapoznik met at Grandma Sally's Restaurant, Stone Park, Illinois and defendant TUCKER gave Sapoznik an envelope.

ff. On or about September 1, 1994, defendants THOMAS R. TUCKER and ROBERT D. NATALE met inside TUCKER's car and had a conversation regarding an adult entertainment ordinance.

gg. On or about September 2 , 1994 , defendants ANTHONY T . CENTRACCHIO and THOMAS R. TUCKER met in the parking lot of the Midwest Bank, Melrose Park, Illinois. Shortly thereafter, defendant TUCKER met with defendant ROBERT S. URBINATI in front of Gran Inc., Melrose Park, Illinois and then drove to the Stone Park Municipal Building.

hh. On or about October 4, 1994, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met at Gramma Sally's Restaurant, River Forest, Illinois. Later that same day, defendant TUCKER met with defendant ROBERT S. URBINATI at Danny's Deli, Melrose Park, Illinois.

ii. On or about October 5, 1994, defendant THOMAS R. TUCKER had a meeting with a Melrose Park law enforcement officer and gave him an envelope.

jj. On or about November 3, 1994, defendant THOMAS R. TUCKER had a meeting with defendant ANTHONY T. CENTRACCHIO at CENTRACCHIO's residence, 2 Kimberly Circle, Oak Brook, Illinois. After meeting with defendant CENTRACCHIO, defendant TUCKER counted a quantity of United States Currency. At one point, defendant TUCKER counted to "775" and said that this would be "Bobby's." defendant TUCKER subsequently met with Seymour Sapoznik at Grandma Sally's Restaurant, Stone Park, Illinois, and sometime after that, a Melrose Park law enforcement officer.

kk. On or about December 2, 1994, defendants ANTHONY T. CENTRACCHIO and THOMAS R. TUCKER met at Centracchio's residence, 2 Kimberly Circle, Oak Brook, Illinois. After leaving Centracchio's

residence, defendant TUCKER counted a quantity of United States Currency. Later that same day, defendant TUCKER met with defendant ROBERT D. NATALE, ROBERT S. URBINATI, and a Melrose Park law enforcement officer at Grandma Sally's Restaurant, Stone Park, Illinois. At Grandma Sally's Restaurant, defendants TUCKER and NATALE met together.

ll. On or about December 2, 1994, defendant THOMAS R. TUCKER possessed 1) a white legal sized envelope marked "Franklin Park" containing a large amount of United States Currency banded together in two separate amounts totaling $1,000 and $775; 2) a sealed, unmarked white envelope containing $500 in United States Currency; 3) a sealed unmarked brown envelope containing $500 in United States Currency; and 4) $500 in United States Currency in his right front pants pocket.

mm. On or about December 2, 1994, defendant ROBERT D. NATALE possessed $1,000 in United States Currency wrapped together by a white band of paper which had the handwritten figure of "1000" on it.

nn. On or about December 3, 1994, defendant THOMAS R. TUCKER met and had a conversation with Seymour Sapoznik.

In violation of Title 18, United States Code, Section 1511.

COUNT FOUR

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

1. At all times material to this Count, ROBERT D. NATALE was the Mayor of the Village of Stone Park, Illinois.

2. On or about December 2, 1994, in Stone Park, in the Northern District of Illinois, Eastern Division,

ROBERT D. NATALE,

defendant herein, committed and attempted to commit extortion, which would and did affect commerce, by knowingly obtaining and attempting to obtain property, namely, money from Anthony T. Centracchio, that is $1,000, with his consent having been induced under color of official right.

In violation of Title 18, United States Code, Sections 1951.

COUNT FIVE

The SPECIAL JANUARY 1999-1 GRAND JURY further charges: On or about May 12, 1994, at 5714 West Division Street, Chicago, in the Northern District of Illinois, Eastern Division, ANTHONY T. CENTRACCHIO, defendant herein, having been convicted of a crime punishable by imprisonment for a term exceeding one year, knowingly possessed a firearm and ammunition, namely:

one 9mm Luger (9x19) Smith and Wesson pistol, model 439, and fifteen 9mm Lugar cartridges, of which the possession of the 9mm Luger Smith and Wesson pistol, and its ammunition, were in and affecting commerce in that they had previously been transported in interstate commerce; In violation of Title 18, United States Code, Section 922(g).

A TRUE BILL: