COUNT ONE

Racketeering Violation
The Grand Jury charges:
The Enterprise

1. At all times relevant to this Indictment, ARNOLD
   SQUITIERI, a/k/a “Bozey,” a/k/a “Zeke,” a/k/a “Sylvester,”
   ANTHONY MEGALE, a/k/a “Mac,” a/k/a “Machiavelli,” GREGORY
   DEPALMA, ALPHONSE SISCA, a/k/a “Funzi,” LOUIS FILIPPELLI, a/k/a
   “Bo,” ROBERT VACCARO, NICHOLAS LASORSA, a/k/a “Nicky,”
   CHRISTOPHER SUCARATO, JOSEPH FORNINO, a/k/a “Joey Per Voi,”
   ROBERT PERSICO, SAM NORDONE, and ROBERT VACCARO, JR., the
   defendants, and others known and unknown, were members and
   associates of the Gambino Organized Crime Family of La Cosa
   Nostra (the “Gambino Organized Crime Family”). The Gambino
   Organized Crime Family was a criminal organization whose members
   and associates engaged in numerous acts of violence and other
   

2. crimes, including: murder; conspiracy to commit murder; attempted
   murder; extortion; labor racketeering; the financing and making
   of extortionate extensions of credit and the collection of
   extensions of credit through extortionate means (commonly known
   as “loansharking”); robbery; money laundering; trafficking in
   counterfeit and stolen goods; and the operation of illegal
   gambling businesses.
   
1. The Gambino Organized Crime Family, including itsleadership, membership, and associates, constituted an“enterprise,” as that term is defined in Title 18, United StatesCode, Section 1961(4) -- that is, a group of individualsassociated in fact, which was engaged in, and the activities ofwhich affected, interstate and foreign commerce. The GambinoOrganized Crime Family was an organized criminal group based inNew York City that operated in the Southern District of New Yorkand elsewhere and constituted an ongoing organization whosemembers functioned as a continuing unit for a common purpose ofachieving the objectives of the enterprise. The GambinoOrganized Crime Family was referred to by its members andassociates in various ways, including as a “cosa nostra,” a“Family,” and “this thing of ours.”

1. The Gambino Organized Crime Family was part of a
   nationwide criminal organization known by various names,
   including the “Mafia” and “La Cosa Nostra” (“LCN”), which
   

2. operated through entities known as “Families.” The GambinoOrganized Crime Family took its name from one of its firstleaders, Carlo Gambino. In addition to the Gambino OrganizedCrime Family, five other Families operated in the New York Cityand New Jersey area, namely, the Genovese Organized Crime Familyof LCN, the Luchese Organized Crime Family of LCN, the ColomboOrganized Crime Family of LCN, the Bonanno Organized Crime Familyof LCN, and the Decavalcante Organized Crime Family of LCN.
2. The Gambino Organized Crime Family operatedthrough groups of individuals known as “crews” and “regimes,”most of which were based in New York City. Each “crew” had asits leader a person known as a “Caporegime,” “Capo,” “Captain,”or “Skipper,” and consisted of “made” members, sometimes known as“Soldiers,” “wiseguys,” “friends of ours,” and “good fellows.” Soldiers were aided in their criminal endeavors by other trustedindividuals, known as “associates,” who sometimes were referredto as “connected” or identified as “with” a Soldier. Associatesparticipated in the various activities of the crew and itsmembers.

1. Each Capo was responsible for supervising the
   criminal activities of his crew and provided Soldiers and
   associates with support and protection. In return, the Capo
   

2. typically received a share of the illegal earnings of each of his
   crew’s Soldiers and associates, which was sometimes referred to
   as “tribute.”
   
3. Above the Capos were the highest-ranking membersof the Gambino Organized Crime Family, commonly referred to asthe Administration. The head of the Gambino Organized CrimeFamily was known as the “Boss,” who was ordinarily assisted by an“Underboss” and a “Consigliere,” or counselor. The Boss,Underboss, and Consigliere were responsible for, among otherthings, setting policy, resolving disputes between and amongmembers of the Gambino Organized Crime Family, and resolvingdisputes between members of the Gambino Organized Crime Familyand members of other criminal organizations. The Administrationof the Gambino Organized Crime Family was also responsible foroverseeing the criminal activities of the Family’s Soldiers andassociates, and made decisions regarding those criminalendeavors.

1. At various times relevant to this Indictment,members of the Gambino Organized Crime Family were temporarilyappointed to serve as Boss, Underboss, Consigliere, or Capo inplace of another member holding that position. Whenever thisoccurred, the member holding the temporary appointment wouldfunction in an “acting” capacity for the other member, whocontinued to hold the “official” position in the Family. In

2. addition, at various times relevant to this Indictment, members
   of the Gambino Organized Crime Family served on a committee or
   ruling panel, a group of high-ranking members of the Family who
   assisted and, at times, made decisions with, or on behalf of, the
   Boss and the Acting Boss of the Family.
   
4. The Boss, Underboss, and Consigliere (whether
   official or acting) and, at times, the members of the ruling
   panel, supervised, supported, protected, and disciplined the
   Capos, Soldiers, and associates, and regularly received reports
   regarding their various activities. In return for their
   supervision and protection, the Boss, Underboss, and Consigliere
   and members of the ruling panel typically received part of the
   illegal earnings of each crew.
   

5. While the overall structure of the GambinoOrganized Crime Family remained constant, the structure of theFamily’s Administration was sometimes adjusted to meet situations-- including particularly the incarceration of the Boss, ActingBoss, and other high-ranking members of the Family -- thatthreatened to impede the orderly operation and criminalactivities of the Gambino Organized Crime Family. Accordingly, following the incarceration of the Gambino Family’s Boss PeterGotti, in or about the second half of 2002, Gambino OrganizedCrime Family Underboss ARNOLD SQUITIERI became the Acting Boss ofthe Gambino Organized Crime Family. At or about the same time,

Gambino Organized Crime Family Soldier ANTHONY MEGALE assumed the
position of Acting Underboss. In many respects, MEGALE operated
as what is sometimes referred to as a “street boss” for SQUITIERI
because of SQUITIERI’s concerns about meeting with other LCN
members and associates while on parole for a prior narcotics
conviction.

The Defendants

10. At all times relevant to this Indictment, ARNOLD
SQUITIERI, a/k/a “Bozey,” a/k/a “Zeke,” a/k/a “Sylvester,”
ANTHONY MEGALE, a/k/a “Mac,” a/k/a “Machiavelli,” GREGORY
DEPALMA, ALPHONSE SISCA, a/k/a “Funzi,” LOUIS FILIPPELLI, a/k/a
“Bo,” ROBERT VACCARO, NICHOLAS LASORSA, a/k/a “Nicky,”
CHRISTOPHER SUCARATO, JOSEPH FORNINO, a/k/a “Joey Per Voi,” SAM
NORDONE, ROBERT PERSICO, and ROBERT VACCARO, JR., the defendants,
and Thomas Cacciopoli, a/k/a “Tommy Sneakers,” were members and
associates of the enterprise, the Gambino Organized Crime Family.
SQUITIERI, MEGALE, DEPALMA, SISCA, FILIPPELLI, VACCARO, LASORSA,
SUCARATO, FORNINO, NORDONE, PERSICO, VACCARO, JR., and Cacciopoli
participated in the operation and management of the enterprise as
follows:

a. ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” was, at various times relevant to this
Indictment, a Soldier, Underboss, and Acting Boss of the Gambino
Organized Crime Family. After being released from prison in or

about March 1999, SQUITIERI was made Underboss of the GambinoOrganized Crime Family, the second highest-ranking position inthe Family, by John J. Gotti, the former Boss of the Family. Following the arrest of Gambino Family Boss Peter Gotti onracketeering charges in June 2002, SQUITIERI became Acting Bossof the Gambino Organized Crime Family, a position he has heldduring much of the time relevant to this Indictment. As ActingBoss, SQUITIERI was responsible for, among other things,supervising the illegal activities of all of the members andassociates of the Gambino Organized Crime Family and resolvingdisputes with other Organized Crime Families. In particular,SQUITIERI regularly received a portion of the proceeds generatedfrom the illegal activities of the Gambino Organized CrimeFamily. At the same time, SQUITIERI tried to avoid meeting withother LCN members and associates because of his concerns aboutlaw enforcement based, in part, on the fact that SQUITIERI iscurrently on parole as a result of a 1989 conviction fordistributing heroin. Notwithstanding these concerns, SQUITIERIhas met with, among others, ANTHONY MEGALE, GREGORY DEPALMA,ALPHONSE SISCA, and ROBERT VACCARO. Among SQUITIERI’s criminalactivities were participation in extortions, the interstatetransportation and receipt of stolen property, and the operationof an illegal gambling business.

b. ANTHONY MEGALE, a/k/a “Mac,” a/k/a

“Machiavelli,” was, at various times relevant to this Indictment,a Soldier and Acting Underboss in the Gambino Organized CrimeFamily. MEGALE became Acting Underboss of the Gambino OrganizedCrime Family at or about the time that ARNOLD SQUITIERI waselevated from Underboss to Acting Boss. In his capacity asActing Underboss, MEGALE was responsible for, among other things,supervising the illegal activities of the members and associatesof the Gambino Organized Crime Family, and resolving disputesbetween and among members and associates of the Gambino OrganizedCrime Family. MEGALE also received a portion of the proceedsfrom the Gambino Organized Crime Family’s illegal activities. Atvarious times relevant to the Indictment, MEGALE assumed directcontrol of certain of GREGORY DEPALMA’s illegal endeavors. Upthrough September 2004, MEGALE met regularly with DEPALMA andother members and associates of the Gambino Organized CrimeFamily to discuss various criminal activities. In September2004, MEGALE was arrested on separate Federal racketeeringcharges in the District of Connecticut, and was detained. Atsuch time, other members of the Gambino Organized Crime Familyassumed certain of MEGALE’s supervisory responsibilities. AmongMEGALE’s criminal activities were participation in extortions,the interstate transportation and receipt of stolen property, andthe operation of an illegal gambling business.

c. GREGORY DEPALMA was, at various times
relevant to this Indictment, a Soldier and Acting Capo in the
Gambino Organized Crime Family. In January 1999, GREGORY DEPALMA
was convicted of Federal racketeering charges in the United

States District Court for the Southern District of New York. Following his release from prison in or about February 2003,DEPALMA retained his position as Acting Capo in the GambinoOrganized Crime Family, the position he had held before hisearlier racketeering conviction. As Acting Capo, DEPALMAsupervised and profited from the illegal activities of theSoldiers and associates in his crew. Among DEPALMA’s criminalactivities were participation in extortions, loansharking, anassault with a deadly weapon, the interstate transportation andreceipt of stolen and counterfeit property, labor racketeering,insurance fraud, and the operation of illegal gamblingbusinesses.

d. ALPHONSE SISCA, a/k/a “Funzi,” was, atvarious times relevant to this Indictment, a Soldier and Capo inthe Gambino Organized Crime Family. SISCA is a close confidanteof ARNOLD SQUITIERI and has attended meetings with other LCNmembers and associates on SQUITIERI’s behalf. Among SISCA’s

criminal activities were participation in extortions and the
operation of an illegal gambling business.

e. LOUIS FILIPPELLI, a/k/a “Bo,” was, at various

times relevant to this Indictment, an associate and Soldier in
the Gambino Organized Crime Family. Following the arrest and

detention in September 2004 of Gambino Organized Crime Family
Acting Underboss ANTHONY MEGALE, FILIPPELLI assumed some of
MEGALE’s supervisory responsibilities. Among FILIPPELLI’s
criminal activities were participation in extortions and the
operation of an illegal gambling business.

f. ROBERT VACCARO was, at various times relevantto this Indictment, an associate and Soldier in the GambinoOrganized Crime Family. In or about August 2003, the GambinoFamily Administration placed VACCARO in DEPALMA’s crew. Thereafter, among other things, VACCARO delivered messagesbetween the Gambino Family Administration and DEPALMA. AmongVACCARO’s criminal activities were participation in extortions,loansharking, an assault with a deadly weapon, interstate

transportation and receipt of stolen property, labor
racketeering, and the operation of illegal gambling businesses.

g.

NICHOLAS LASORSA, a/k/a “Nicky,” was, at
various times relevant to this Indictment, a Soldier in the
Gambino Organized Crime Family. Among LASORSA’s criminal
activities were participation in extortions.

h.

CHRISTOPHER SUCARATO was, at various times
relevant to this Indictment, an associate in the Gambino
Organized Crime Family. Among SUCARATO’s criminal activities
were participation in extortions.

i.

JOSEPH FORNINO, a/k/a “Joey Per Voi,” was, at
various times relevant to this Indictment, an associate in the

Gambino Organized Crime Family. FORNINO owned the Pasta Per VoiRestaurant, in Port Chester, New York, where MEGALE, DEPALMA,VACCARO and other Gambino Organized Crime Family members andassociates met. Among FORNINO’s criminal activities wereloansharking, interstate transportation and receipt of stolenproperty, and operation of an illegal gambling business.

j.

SAM NORDONE was, at various times relevant tothis Indictment, an associate in the Gambino Organized CrimeFamily. NORDONE ran the Sam Nordone & Sons’ Autobody Shop inLarchmont, New York. Among NORDONE’s criminal activities werethe interstate transportation and receipt of stolen property,labor racketeering, and insurance fraud.

k.

ROBERT PERSICO was, at various times relevant
to this Indictment, an associate in the Gambino Organized Crime
Family. PERSICO operated a construction business in Westchester
County, New York. Among PERSICO’s criminal activities were
participation in an extortion and the interstate transportation
and receipt of stolen property.

l.

ROBERT VACCARO, JR. was, at various timesrelevant to this Indictment, an associate in the GambinoOrganized Crime Family. VACCARO, JR. is the son of GambinoOrganized Crime Family Soldier ROBERT VACCARO. Among VACCARO,JR.’s criminal activities were labor racketeering and interstatetransportation and receipt of stolen property.

m. Thomas Cacciopoli was, at various times

relevant to this Indictment, a Soldier and Capo in the Gambino
Organized Crime Family. Among Cacciopoli’s criminal activities
were participation in extortions.

Purposes of the Enterprise

11. The purposes of the enterprise included the
following:

a.

Enriching the leaders, members, and
associates of the enterprise through, among other things: (i) the
extortionate control of businesses, labor unions, persons, and
property through threats of physical and economic harm; (ii) the
financing, extension, and collection of extortionate extensions
of credit, commonly known as “loansharking”; (iii) the operation
of illegal gambling businesses; (iv) the purchase, sale and
receipt of stolen property and counterfeit goods; (v) theft; (vi)
labor racketeering; and (vii) automobile insurance fraud;

b.

Preserving and augmenting the power,
territory, and financial profits of the enterprise through
murder, intimidation, violence, and threats of physical and
economic harm; and

c.

Keeping victims and citizens in fear of the
enterprise and its leaders, members and associates by: (i)
identifying the enterprise, its members, and its associates with
La Cosa Nostra or the “Mafia”; (ii) causing and threatening to

cause economic harm; and (iii) committing and threatening to
commit physical violence.

Means and Methods of the Enterprise

12. Among the means and methods by which the
defendants and other enterprise members and associates conducted
and participated in the conduct of the affairs of the enterprise
were the following:

a.

To protect and expand the enterprise’s
business and criminal operations, members and associates of the
enterprise murdered, threatened to murder, and assaulted persons
who engaged in activity that jeopardized (i) the power and
criminal activities of the enterprise and the power and criminal
activities of fellow LCN Families, (ii) the power of leaders of
the enterprise, and (iii) the flow of criminal proceeds to the
leaders of the enterprise.

b.

Members and associates of the enterprise
promoted a climate of fear in the community through threats of
economic harm and violence.

c.

Members and associates of the enterprise
generated income for the enterprise through, among other things,

(i)

extortion; (ii) loansharking; (iii) the operation of illegal
gambling businesses, including a lucrative numbers operation;

(iv)

labor racketeering; (v) the purchase, sale, and receipt of

stolen property and counterfeit goods; (vi) theft; and (vii)
automobile insurance fraud.

d.

Members and associates of the enterprise at
times engaged in criminal conduct or coordinated their criminal
activities with leaders, members, and associates of other LCN
Families. At other times, members and associates of the
enterprise met with leaders, members and associates of other LCN
Families to resolve disputes over their criminal activities.

e.

Members and associates of the enterprise usedvarious techniques to avoid law enforcement scrutiny of theenterprise’s criminal activities. Members and associates of theenterprise typically used coded language to make arrangements formeetings and to refer to other members and associates of theenterprise, met at surreptitious meeting locations, often insecluded or out-of-the-way areas, changed automobiles whentraveling to such meetings, and engaged in “walk and talks.” Inparticular, GREGORY DEPALMA, the defendant, frequently metmembers of his crew and other members and associates of theGambino Organized Crime Family and other LCN Families at theUnited Hebrew Geriatric Center, located in New Rochelle, NewYork, where DEPALMA’s son Craig, a Gambino Family soldier, is apatient. Members and associates of the enterprise also engagedin other evasive conduct, such as whispering and speaking inhushed tones in an effort to obstruct potential law enforcement

eavesdropping, and not specifying the names of those about whom
they were speaking.

f.

Members and associates of the enterprise
attempted to identify and did identify individuals suspected of
providing, or deemed likely to provide, information to law
enforcement about the enterprise, its members and activities, and
about other LCN Families.

g.

To conceal their receipt of money generated
from their criminal activities, members and associates of the
enterprise concealed their ownership of various assets that were
purchased with proceeds of their criminal activities.

The Racketeering Violation

13. From at least in or about the early 1990s, up
through and including in or about March 2005, in the Southern
District of New York and elsewhere, ARNOLD SQUITIERI, a/k/a
“Bozey,” a/k/a “Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a
“Mac,” a/k/a “Machiavelli,” GREGORY DEPALMA, ALPHONSE SISCA,
a/k/a “Funzi,” LOUIS FILIPPELLI, a/k/a “Bo,” ROBERT VACCARO,
NICHOLAS LASORSA, a/k/a “Nicky,” CHRISTOPHER SUCARATO, JOSEPH
FORNINO, a/k/a “Joey Per Voi,” SAM NORDONE, ROBERT PERSICO, and
ROBERT VACCARO, JR., the defendants, and others known and
unknown, being persons employed by and associated with the
racketeering enterprise described in Paragraphs 1 through 12
above, namely, the Gambino Organized Crime Family, which

enterprise was engaged in, and the activities of which affected,
interstate and foreign commerce, unlawfully, willfully, and
knowingly conducted and participated, directly and indirectly, in
the conduct of the affairs of that enterprise through a pattern
of racketeering activity, as that term is defined in Title 18,
United States Code, Sections 1961(1) and 1961(5), that is,
through the commission of the following racketeering acts:

The Pattern of Racketeering

14. The pattern of racketeering activity, as defined
in Title 18, United States Code, Sections 1961(1) and 1961(5),
consisted of the following acts:

COUNT TWO

The Racketeering Conspiracy
The Grand Jury further charges:

1. Paragraphs 1 through 12 and 14 through 36 of this
   Indictment are repeated and realleged and incorporated by
   reference as though fully set forth herein.
   

2. From in or about the early 1990s, up through and
   including in or about March 2005, in the Southern District of New
   York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
   “Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
   “Machiavelli,” GREGORY DEPALMA, ALPHONSE SISCA, a/k/a “Funzi,”
   LOUIS FILIPPELLI, a/k/a “Bo,” ROBERT VACCARO, NICHOLAS LASORSA,
   a/k/a “Nicky,” CHRISTOPHER SUCARATO, JOSEPH FORNINO, a/k/a “Joey
   Per Voi,” ROBERT PERSICO, SAM NORDONE, and ROBERT VACCARO, JR.,
   the defendants, and others known and unknown, being persons
   employed by and associated with the racketeering enterprise
   described in Paragraphs 1 through 12 above, namely, the Gambino
   Organized Crime Family, which enterprise was engaged in, and the
   activities of which affected, interstate and foreign commerce,
   unlawfully, willfully, and knowingly combined, conspired,
   confederated, and agreed together and with each other to conduct
   and participate, directly and indirectly, in the conduct of the
   affairs of that enterprise through a pattern of racketeering
   

activity, as that term is defined in Title 18, United StatesCode, Sections 1961(1) and 1961(5), which pattern is set forthmore fully in paragraphs 14 through 36 above, as RacketeeringActs One through Twenty-Two. It was a further part and an objectof the conspiracy that each defendant agreed that a conspiratorwould commit at least two acts of racketeering activity in theconduct of the affairs of the enterprise.

(Title 18, United States Code, Section 1962(d).)

VIOLENT CRIME IN AID OF RACKETEERING

COUNT THREE

(Assault of Victim #3 In Aid of Racketeering)

The Grand Jury further charges:

1. At all times relevant to this Indictment, the
   Gambino Organized Crime Family, as more fully described in
   Paragraphs 1 through 12 of this Indictment, which are repeated,
   realleged, and incorporated by reference as though set forth
   fully herein, constituted an "enterprise," as that term is
   defined in Title 18, United States Code, Section 1959(b)(2), that
   is, a group of individuals associated in fact, although not a
   legal entity, which was engaged in, and the activities of which
   affected, interstate and foreign commerce.
   

1. At all times relevant to this Indictment, the
   above-described enterprise, through its members and associates,
   engaged in racketeering activity, as that term is defined in
   

2. Title 18, United States Code, Sections 1959(b)(1) and 1961(1),
   namely, acts indictable under Title 18, United States Code,
   Section 1951 (extortion), acts indictable under Title 18, United
   States Code, Section 894 (extortionate collection of debts), acts
   indictable under Title 18, United States Code, Section 892
   (making of extortionate extensions of credit), acts indictable
   under Title 18, United States Code, Sections 1084 and 1955
   (illegal gambling business), acts indictable under Title 18,
   United States Code, Sections 2312, 2313, 2314, and 2315 (sale,
   purchase, transportation and possession of stolen property), acts
   indictable under Title 18, United States Code, Section 2320
   (trafficking in counterfeit goods), and acts involving illegal
   gambling, in violation of New York State Penal Law.
   
2. In or about February 2005, in the Southern
   District of New York and elsewhere, for the purpose of
   maintaining and increasing their positions in the Gambino
   Organized Crime Family, an enterprise engaged in racketeering
   activity, GREGORY DEPALMA and ROBERT VACCARO, the defendants, and
   others known and unknown, unlawfully, willfully, and knowingly
   did assault Victim #3 with a deadly weapon, to wit, DEPALMA and
   VACCARO struck Victim #3 over the head with a deadly weapon,
   resulting in serious head injuries to Victim #3, in violation of
   New York State Penal Law, Sections 120.05(1) and (2), and 20.00.
   

(Title 18, United States Code, Sections 1959(a)(3) and 2.)

COUNT FOUR

(Conspiracy To Extort The Owner Of A Restaurant
Located In Greenwich, Connecticut)

The Grand Jury further charges:

42. From in or about 1998, up through and including in
or about March 2005, in the Southern District of New York and
elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a “Zeke,” a/k/a
“Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a “Machiavelli,”
GREGORY DEPALMA, LOUIS FILIPPELLI, a/k/a “Bo,” ROBERT VACCARO,
and NICHOLAS LASORSA, a/k/a “Nicky,” the defendants, and others
known and unknown, unlawfully, willfully, and knowingly did
combine, conspire, confederate, and agree together and with each
other to commit extortion, as that term is defined in Title 18,
United States Code, Section 1951(b)(2), by obtaining money and
property from and with the consent of another person, to wit, the
owner and operator of a restaurant in Greenwich, Connecticut,
which consent would have been and was induced by the wrongful use
of actual and threatened force, violence, and fear, and thereby
would and did obstruct, delay, and affect commerce and the
movement of articles and commodities in commerce, as that term is
defined in Title 18, United States Code, Section 1951(b)(3).

(Title 18, United States Code, Section 1951.)

COUNT FIVE

(Extortion Of The Owner Of A Restaurant
Located In Greenwich, Connecticut)

The Grand Jury further charges:

43. From in or about 1998, up through and including in
or about March 2005, in the Southern District of New York and
elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a “Zeke,” a/k/a
“Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a “Machiavelli,”
GREGORY DEPALMA, LOUIS FILIPPELLI, a/k/a “Bo,” ROBERT VACCARO and
NICHOLAS LASORSA, a/k/a “Nicky,” the defendants, and others known
and unknown, unlawfully, willfully, and knowingly did commit
extortion, as that term is defined in Title 18, United States
Code, Section 1951(b)(2), by obtaining money and property from
and with the consent of another, to wit, the owner and operator
of a restaurant in Greenwich, Connecticut, which consent was
induced by the wrongful use of actual and threatened force,
violence, and fear, and thereby did obstruct, delay, and affect
commerce and the movement of articles and commodities in
commerce, as that term is defined in Title 18, United States
Code, Section 1951(b)(3).

(Title 18, United States Code, Sections 1951 and 2.)

COUNT SIX

(Conspiracy To Extort A Construction Company
Located In Mineola, New York)

The Grand Jury further charges:

44. From in or about September 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, LOUIS FILIPPELLI, a/k/a “Bo,”
THOMAS CACCIOPOLI, a/k/a “Tommy Sneakers,” and ROBERT VACCARO,
the defendants, and others known and unknown, unlawfully,
willfully, and knowingly did combine, conspire, confederate, and
agree together and with each other to commit extortion, as that
term is defined in Title 18, United States Code, Section
1951(b)(2), by obtaining money and property from and with the
consent of other persons, to wit, the owners and operators of a
construction company in Mineola, New York, which consent would
have been and was induced by the wrongful use of actual and
threatened force, violence, and fear, and thereby would and did
obstruct, delay, and affect commerce and the movement of articles
and commodities in commerce, as that term is defined in Title 18,
United States Code, Section 1951(b)(3).

(Title 18, United States Code, Section 1951.)

COUNT SEVEN

(Extortion Of A Construction Company
Located In Mineola, New York)

The Grand Jury further charges:

45. From in or about September 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, LOUIS FILIPPELLI, a/k/a “Bo,”
THOMAS CACCIOPOLI, a/k/a “Tommy Sneakers,” and ROBERT VACCARO,
the defendants, and others known and unknown, unlawfully,
willfully, and knowingly did commit extortion, as that term is
defined in Title 18, United States Code, Section 1951(b)(2), by
obtaining money and property from and with the consent of others,
to wit, the owners and operators of a construction company in
Mineola, New York, which consent was induced by the wrongful use
of actual and threatened force, violence, and fear, and thereby
did obstruct, delay, and affect commerce and the movement of
articles and commodities in commerce, as that term is defined in
Title 18, United States Code, Section 1951(b)(3).

(Title 18, United States Code, Sections 1951 and 2.)

COUNT EIGHT

(Conspiracy To Extort A Construction Company
Located In Staten Island, New York)

The Grand Jury further charges:

46. From in or about September 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” and THOMAS CACCIOPOLI, a/k/a “Tommy
Sneakers,” the defendants, and others known and unknown,
unlawfully, willfully, and knowingly did combine, conspire,
confederate, and agree together and with each other to commit
extortion, as that term is defined in Title 18, United States
Code, Section 1951(b)(2), by obtaining money and property from
and with the consent of other persons, to wit, the owners and
operators of a construction company in Staten Island, New York,
which consent would have been and was induced by the wrongful use
of actual and threatened force, violence, and fear, and thereby
would and did obstruct, delay, and affect commerce and the
movement of articles and commodities in commerce, as that term is
defined in Title 18, United States Code, Section 1951(b)(3).

(Title 18, United States Code, Section 1951.)

COUNT NINE

(Extortion Of A Construction Company
Located In Staten Island, New York)

The Grand Jury further charges:

47. From in or about September 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” and THOMAS CACCIOPOLI, a/k/a “Tommy
Sneakers,” the defendants, and others known and unknown,
unlawfully, willfully, and knowingly did commit extortion, as
that term is defined in Title 18, United States Code, Section
1951(b)(2), by obtaining money and property from and with the
consent of others, to wit, the owners and operators of a
construction company in Staten Island, New York, which consent
was induced by the wrongful use of actual and threatened force,
violence, and fear, and thereby did obstruct, delay, and affect
commerce and the movement of articles and commodities in
commerce, as that term is defined in Title 18, United States
Code, Section 1951(b)(3).

(Title 18, United States Code, Sections 1951 and 2.)

COUNT TEN

(Conspiracy To Extort Victim #1)
The Grand Jury further charges:

48. From in or about June 2003, up through and
including in or about March 2005, in the Southern District of New

York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” ALPHONSE SISCA, a/k/a “Funzi,” GREGORY DEPALMA,
ROBERT VACCARO, CHRISTOPHER SUCARATO, and FRANK D’AGOSTINO, a/k/a
“Frankie D,” the defendants, and others known and unknown,
unlawfully, willfully, and knowingly did combine, conspire,
confederate, and agree together and with each other to commit
extortion, as that term is defined in Title 18, United States
Code, Section 1951(b)(2), by obtaining money and property from
and with the consent of another person, to wit, Victim #1, which
consent would have been and was induced by the wrongful use of
actual and threatened force, violence, and fear, and thereby
would and did obstruct, delay, and affect commerce and the
movement of articles and commodities in commerce, as that term is
defined in Title 18, United States Code, Section 1951(b)(3).

(Title 18, United States Code, Section 1951.)

COUNT ELEVEN

(Extortion Of Victim #1)
The Grand Jury further charges:

49. From in or about June 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, ALPHONSE SISCA, a/k/a “Funzi,”

ROBERT VACCARO, CHRISTOPHER SUCARATO, and FRANK D’AGOSTINO, a/k/a
“Frankie D,” the defendants, and others known and unknown,
unlawfully, willfully, and knowingly did commit extortion, as
that term is defined in Title 18, United States Code, Section
1951(b)(2), by obtaining money and property from and with the
consent of another, to wit, Victim #1, which consent was induced
by the wrongful use of actual and threatened force, violence, and
fear, and thereby did obstruct, delay, and affect commerce and
the movement of articles and commodities in commerce, as that
term is defined in Title 18, United States Code, Section
1951(b)(3).

(Title 18, United States Code, Sections 1951 and 2.)

COUNT TWELVE

(Conspiracy To Extort A Trucking
Company Located In New Jersey)

The Grand Jury further charges:

50. From in or about September 2003, up through and
including in or about February 2005, in the Southern District of
New York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, LOUIS FILIPPELLI, a/k/a “Bo,” and
ROBERT VACCARO, the defendants, and others known and unknown,
unlawfully, willfully, and knowingly did combine, conspire,
confederate, and agree together and with each other to commit
extortion, as that term is defined in Title 18, United States

Code, Section 1951(b)(2), by obtaining money and property from
and with the consent of other persons, to wit, the owners and
operators of a trucking company in New Jersey, which consent
would have been and was induced by the wrongful use of actual and
threatened force, violence, and fear, and thereby would and did
obstruct, delay, and affect commerce and the movement of articles
and commodities in commerce, as that term is defined in Title 18,
United States Code, Section 1951(b)(3).

(Title 18, United States Code, Section 1951.)

COUNT THIRTEEN

(Extortion Of A Trucking Company Located In New Jersey)
The Grand Jury further charges:

51. From in or about September 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, LOUIS FILIPPELLI, a/k/a “Bo,” and
ROBERT VACCARO, the defendants, and others known and unknown,
unlawfully, willfully, and knowingly did commit extortion, as
that term is defined in Title 18, United States Code, Section
1951(b)(2), by obtaining money and property from and with the
consent of others, to wit, the owners and operators of a trucking
company in New Jersey, which consent was induced by the wrongful
use of actual and threatened force, violence, and fear, and

thereby did obstruct, delay, and affect commerce and the movement
of articles and commodities in commerce, as that term is defined
in Title 18, United States Code, Section 1951(b)(3).

(Title 18, United States Code, Sections 1951 and 2).

COUNT FOURTEEN

(Conspiracy To Extort A Construction Company
Located In Westchester County, New York)

The Grand Jury further charges:

52. From in or about the early 1990s, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, ROBERT VACCARO, and ROBERT
PERSICO, the defendants, and others known and unknown,
unlawfully, willfully, and knowingly did combine, conspire,
confederate, and agree together and with each other to commit
extortion, as that term is defined in Title 18, United States
Code, Section 1951(b)(2), by obtaining money and property from
and with the consent of another person, to wit, the owners and
operators of a construction company located in Westchester
County, New York, which consent would have been and was induced
by the wrongful use of actual and threatened force, violence, and
fear, and thereby would and did obstruct, delay, and affect
commerce and the movement of articles and commodities in

commerce, as that term is defined in Title 18, United States
Code, Section 1951(b)(3).
(Title 18, United States Code, Section 1951.)

COUNT FIFTEEN

(Extortion Of A Construction Company
Located In Westchester County, New York)

The Grand Jury further charges:

53. From in or about the early 1990s, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, ROBERT VACCARO, and ROBERT
PERSICO, the defendants, and others known and unknown,
unlawfully, willfully, and knowingly did commit extortion, as
that term is defined in Title 18, United States Code, Section
1951(b)(2), by obtaining money and property from and with the
consent of another, to wit, the owners and operators of a
construction company in Westchester County, New York, which
consent was induced by the wrongful use of actual and threatened
force, violence, and fear, and thereby did obstruct, delay, and
affect commerce and the movement of articles and commodities in
commerce, as that term is defined in Title 18, United States
Code, Section 1951(b)(3).

(Title 18, United States Code, Sections 1951 and 2.)

COUNT SIXTEEN

(Conspiracy To Extort A
Nightclub Owner In The Bronx, New York)

The Grand Jury further charges:

54. From in or about February 1998, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, ALPHONSE SISCA, a/k/a “Funzi,”
LOUIS FILIPPELLI, a/k/a “Bo,” NICHOLAS LASORSA, a/k/a “Nicky,”
and CHRISTOPHER SUCARATO, the defendants, and others known and
unknown, unlawfully, willfully, and knowingly did combine,
conspire, confederate, and agree together and with each other to
commit extortion, as that term is defined in Title 18, United
States Code, Section 1951(b)(2), by obtaining money and property
from and with the consent of another person, to wit, the owner
and operator of nightclubs in the Bronx, New York, which consent
would have been and was induced by the wrongful use of actual and
threatened force, violence, and fear, and thereby would and did
obstruct, delay, and affect commerce and the movement of articles
and commodities in commerce, as that term is defined in Title 18,
United States Code, Section 1951(b)(3).

(Title 18, United States Code, Section 1951.)

COUNT SEVENTEEN

(Extortion Of A Nightclub Owner In The Bronx, New York)
The Grand Jury further charges:

55. From in or about February 1998, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, ALPHONSE SISCA, a/k/a “Funzi,”
LOUIS FILIPPELLI, a/k/a “Bo,” NICHOLAS LASORSA, a/k/a “Nicky,”
and CHRISTOPHER SUCARATO, the defendants, and others known and
unknown, unlawfully, willfully, and knowingly did commit
extortion, as that term is defined in Title 18, United States
Code, Section 1951(b)(2), by obtaining money and property from
and with the consent of another person, to wit, the owner and
operator of nightclubs in the Bronx, New York, which consent was
induced by the wrongful use of actual and threatened force,
violence, and fear, and thereby did obstruct, delay, and affect
commerce and the movement of articles and commodities in
commerce, as that term is defined in Title 18, United States
Code, Section 1951(b)(3).

(Title 18, United States Code, Sections 1951 and 2.)

COUNT EIGHTEEN

(Conspiracy to Extort A New York City Radio Station)
The Grand Jury further charges:

56. From in or about July 2003, up through and
including in or about October 2003, in the Southern District of
New York and elsewhere, ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, LOUIS FILIPPELLI, a/k/a “Bo,”
ROBERT VACCARO, and JOSEPH FORNINO, a/k/a “Joey Per Voi,” the
defendants, and others known and unknown, unlawfully, willfully,
and knowingly did combine, conspire, confederate, and agree
together and with each other to commit extortion, as that term is
defined in Title 18, United States Code, Section 1951(b)(2), by
obtaining property from and with the consent of other persons, to
wit, the employees, contractors, and agents of a New York City
radio station, which consent would have been and was induced by
the wrongful use of actual and threatened force, violence, and
fear, and thereby would and did obstruct, delay, and affect
commerce and the movement of articles and commodities in
commerce, as that term is defined in Title 18, United States
Code, Section 1951(b)(3).

(Title 18, United States Code, Section 1951.)

COUNT NINETEEN

(Extortion Of A New York City Radio Station)

The Grand Jury further charges:

57. From in or about July 2003, up through and
including in or about October 2003, in the Southern District of
New York and elsewhere, ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, LOUIS FILIPPELLI, ROBERT VACCARO,
and JOSEPH FORNINO, a/k/a “Joey Per Voi,” the defendants, and
others known and unknown, unlawfully, willfully, and knowingly
did commit extortion, as that term is defined in Title 18, United
States Code, Section 1951(b)(2), by obtaining property from and
with the consent of others, to wit, the employees, contractors
and agents of a New York City radio station, which consent was
induced by the wrongful use of actual and threatened force,
violence, and fear, and thereby did obstruct, delay, and affect
commerce and the movement of articles and commodities in
commerce, as that term is defined in Title 18, United States
Code, Section 1951(b)(3).

(Title 18, United States Code, Sections 1951 and 2.)

COUNT TWENTY

(Conspiracy To Extort A Second Construction
Company Located In Westchester County, New York)

The Grand Jury further charges:

58. From in or about September 2003, up through and
including in or about March 2005, in the Southern District of New

York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” GREGORY DEPALMA and ROBERT VACCARO,
the defendants, and others known and unknown, unlawfully,
willfully, and knowingly did combine, conspire, confederate, and
agree together and with each other to commit extortion, as that
term is defined in Title 18, United States Code, Section
1951(b)(2), by obtaining money and property from and with the
consent of other persons, to wit, the owners and operators of a
second construction company in Westchester County, New York,
which consent would have been and was induced by the wrongful use
of actual and threatened force, violence, and fear, and thereby
would and did obstruct, delay, and affect commerce and the
movement of articles and commodities in commerce, as that term is
defined in Title 18, United States Code, Section 1951(b)(3).

(Title 18, United States Code, Section 1951.)

COUNT TWENTY-ONE

(Extortion Of A Second Construction Company
Located In Westchester County, New York)

The Grand Jury further charges:

59. From in or about September 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” GREGORY DEPALMA and ROBERT VACCARO,
the defendants, and others known and unknown, unlawfully,
willfully, and knowingly did commit extortion, as that term is

defined in Title 18, United States Code, Section 1951(b)(2), by
obtaining money and property from and with the consent of others,
to wit, the owners and operators of a second construction company
in Westchester County, New York, which consent was induced by the
wrongful use of actual and threatened force, violence, and fear,
and thereby did obstruct, delay, and affect commerce and the
movement of articles and commodities in commerce, as that term is
defined in Title 18, United States Code, Section 1951(b)(3).

(Title 18, United States Code, Sections 1951 and 2.)

COUNT TWENTY-TWO

(Conspiracy To Extort A Third Construction
Company Located In Westchester County, New York)

The Grand Jury further charges:

60. From in or about June 2004, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA, and ROBERT VACCARO, the
defendants, and others known and unknown, unlawfully, willfully,
and knowingly did combine, conspire, confederate, and agree
together and with each other to commit extortion, as that term is
defined in Title 18, United States Code, Section 1951(b)(2), by
obtaining money and property from and with the consent of another
person, to wit, the owner and operator of a third construction
company in Westchester County, New York, which consent would have

been and was induced by the wrongful use of actual and threatened
force, violence, and fear, and thereby would and did obstruct,
delay, and affect commerce and the movement of articles and
commodities in commerce, as that term is defined in Title 18,
United States Code, Section 1951(b)(3)

(Title 18, United States Code, Section 1951.)

COUNT TWENTY-THREE

(Extortion Of A Third Construction Company
Located In Westchester County, New York)

The Grand Jury further charges:

61. From in or about June 2004, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
“Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA and ROBERT VACCARO, the
defendants, and others known and unknown, unlawfully, willfully,
and knowingly did commit extortion, as that term is defined in
Title 18, United States Code, Section 1951(b)(2), by obtaining
money and property from and with the consent of another person,
to wit, the owner and operator of a third construction company in
Westchester County, New York, which consent was induced by the
wrongful use of actual and threatened force, violence, and fear,
and thereby did obstruct, delay, and affect commerce and the
movement of articles and commodities in commerce, as that term is

defined in Title 18, United States Code, Section 1951(b)(3).
(Title 18, United States Code, Sections 1951 and 2.)

COUNT TWENTY-FOUR

(Conspiracy To Extort A Construction
Company Located In Rockland County, New York)

The Grand Jury further charges:

62. From in or about July 2004, up through and
including in or about August 2004, in the Southern District of
New York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, and NEIL
DELIETO, the defendants, and others known and unknown,
unlawfully, willfully, and knowingly did combine, conspire,
confederate, and agree together and with each other to commit
extortion, as that term is defined in Title 18, United States
Code, Section 1951(b)(2), by obtaining money and property from
and with the consent of other persons, to wit, the owners and
operators of a construction company in Rockland County, New York,
which consent would have been and was induced by the wrongful use
of actual and threatened force, violence, and fear, and thereby
would and did obstruct, delay, and affect commerce and the
movement of articles and commodities in commerce, as that term is
defined in Title 18, United States Code, Section 1951(b)(3).

(Title 18, United States Code, Section 1951.)

COUNT TWENTY-FIVE

(Attempted Extortion Of A Construction
Company Located In Rockland County, New York)

The Grand Jury further charges:

63. From in or about July 2004, up through and
including in or about August 2004, in the Southern District of
New York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, and NEIL
DELIETO, the defendants, and others known and unknown,
unlawfully, willfully, and knowingly did attempt to commit
extortion, as that term is defined in Title 18, United States
Code, Section 1951(b)(2), by attempting to obtain money and
property from and with the consent of others, to wit, the owners
and operators of a construction company in Rockland County, New
York, which consent would have been and was induced by the
wrongful use of actual and threatened force, violence, and fear,
and thereby would and did obstruct, delay, and affect commerce
and the movement of articles and commodities in commerce, as that
term is defined in Title 18, United States Code, Section
1951(b)(3).

(Title 18, United States Code, Sections 1951 and 2.)

COUNT TWENTY-SIX

(Conspiracy To Extort A Concrete Company
Located In Westchester County, New York)

The Grand Jury further charges:

64. From in or about August 2003, up through and
including in or about May 2004, in the Southern District of New
York and elsewhere, ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA and ROBERT VACCARO, the
defendants, and others known and unknown, unlawfully, willfully,
and knowingly did combine, conspire, confederate, and agree
together and with each other to commit extortion, as that term is
defined in Title 18, United States Code, Section 1951(b)(2), by
obtaining money and property from and with the consent of other
persons, to wit, the owners and operators of a concrete company
in Westchester County, New York, which consent would have been
and was induced by the wrongful use of actual and threatened
force, violence, and fear, and thereby would and did obstruct,
delay, and affect commerce and the movement of articles and
commodities in commerce, as that term is defined in Title 18,
United States Code, Section 1951(b)(3).

(Title 18, United States Code, Section 1951.)

COUNT TWENTY-SEVEN

(Extortion Of A Concrete Company
Located In Westchester County, New York)

The Grand Jury further charges:

65. From in or about August 2003, up through and
including in or about May 2004, in the Southern District of New
York and elsewhere, ANTHONY MEGALE, a/k/a “Mac,” a/k/a
“Machiavelli,” GREGORY DEPALMA and ROBERT VACCARO, the
defendants, and others known and unknown, unlawfully, willfully,
and knowingly did commit extortion, as that term is defined in
Title 18, United States Code, Section 1951(b)(2), by obtaining
money and property from and with the consent of others, to wit,
the owners and operators of a concrete company in Westchester
County, New York, which consent was induced by the wrongful use
of actual and threatened force, violence, and fear, and thereby
did obstruct, delay, and affect commerce and the movement of
articles and commodities in commerce, as that term is defined in
Title 18, United States Code, Section 1951(b)(3).

(Title 18, United States Code, Sections 1951 and 2.)

COUNT TWENTY-EIGHT

(Conspiracy To Operate An Illegal Numbers Business)

The Grand Jury further charges:

1. From in or about the early 1990s, up through and
   including in or about March 2005, in the Southern District of New
   York and elsewhere, ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a
   

2. “Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a
   “Machiavelli,” GREGORY DEPALMA, ALPHONSE SISCA, a/k/a “Funzi,”
   LOUIS FILIPPELLI, a/k/a “Bo,” ROBERT VACCARO, LEONARD MINUTO,
   SR., a/k/a “Lenny,” LEONARD MINUTO, JR., a/k/a “Lenny,” LOUIS
   NATRELLA, a/k/a “Little Louie,” FRANK BUSCEMI, a/k/a “Cheech,”
   JOHN VACCARO, a/k/a “Popcorn,” and PAUL OLIVERI, the defendants,
   and others known and unknown, unlawfully, willfully, and
   knowingly did combine, conspire, confederate, and agree together
   and with each other to commit an offense against the United
   States, to wit, to violate Title 18, United States Code, Section
   1955.
   
1. It was a part and an object of said conspiracy
   that ARNOLD SQUITIERI, a/k/a “Bozey,” a/k/a “Zeke,” a/k/a
   “Sylvester,” ANTHONY MEGALE, a/k/a “Mac,” a/k/a “Machiavelli,”
   GREGORY DEPALMA, ALPHONSE SISCA, a/k/a “Funzi,” LOUIS FILIPPELLI,
   a/k/a “Bo,” ROBERT VACCARO, LEONARD MINUTO, SR., a/k/a “Lenny,”
   LEONARD MINUTO, JR., a/k/a “Lenny,” LOUIS NATRELLA, a/k/a “Little
   Louie,” FRANK BUSCEMI, a/k/a “Cheech,” JOHN VACCARO, a/k/a
   “Popcorn,” and PAUL OLIVERI, the defendants, and others known and
   unknown, unlawfully, willfully and knowingly would and did
   conduct, finance, manage, supervise, direct, and own all and part
   of an illegal gambling business, namely, an illegal numbers
   operation, in violation of New York State Penal Law, Sections
   

225.00 and 225.10, and which business would and did involve five

and more persons who conducted, financed, managed, supervised,
directed, and owned all and part of it, and which business would
and did remain in substantially continuous operation for a period
in excess of thirty days and have gross revenues of $2,000 in a
single day, in violation of Title 18, United States Code, Section
1955.

Overt Acts

68. In furtherance of said conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed:

a.

In or about April 2004, GREGORY DEPALMA met
LEONARD MINUTO, JR. in Westchester County, New York.

b.

On or about April 5, 2004, ROBERT VACCARO
spoke on the telephone with JOHN VACCARO.

c.

On or about June 4, 2004, DEPALMA met with
ROBERT VACCARO and LEONARD MINUTO, SR. in Westchester County, New
York.

d.

On or about August 31, 2004, an individual
(“Individual #1") met FRANK BUSCEMI, a/k/a “Cheech,” at a
location in Westchester County, New York.

e.

On or about September 22, 2004, DEPALMA,
VACCARO and ALPHONSE SISCA, a/k/a “Funzi,” met at a restaurant in
Manhattan.

f.

On or about November 10, 2004, DEPALMA,
VACCARO and LOUIS NATRELLA, a/k/a “Little Louie,” met in
Westchester County, New York.

g.

On or about December 12, 2004, PAUL OLIVERI
met LOUIS NATRELLA at 744A Morris Park Avenue, in the Bronx, New
York.

h. On or about January 25, 2005, DEPALMA met

LOUIS FILIPPELLI at a location in Westchester County, New York.
(Title 18, United States Code, Section 371.)
COUNT TWENTY-NINE

(Operation Of An Illegal Numbers Business)
The Grand Jury further charges:

69. From at least in or about the early 1990s, up
through and including in or about March 2005, in the Southern
District of New York and elsewhere, ARNOLD SQUITIERI, a/k/a
“Bozey,” a/k/a “Zeke,” a/k/a “Sylvester,” ANTHONY MEGALE, a/k/a
“Mac,” a/k/a “Machiavelli,” GREGORY DEPALMA, ALPHONSE SISCA,
a/k/a “Funzi,” LOUIS FILIPPELLI, a/k/a “Bo,” ROBERT VACCARO,
LEONARD MINUTO, SR., a/k/a “Lenny,” LEONARD MINUTO, JR., a/k/a
“Lenny,” LOUIS NATRELLA, a/k/a “Little Louie,” FRANK BUSCEMI,
a/k/a “Cheech,” JOHN VACCARO, a/k/a “Popcorn,” and PAUL OLIVERI,
the defendants, and others known and unknown, unlawfully,
willfully, and knowingly conducted, financed, managed,
supervised, directed, and owned all and part of an illegal

gambling business, namely, an illegal numbers operation, in

violation of New York State Penal Law Sections 225.00 and 225.10,

and which business involved five and more persons who conducted,
financed, managed, supervised, directed, and owned all and part
of it, and which business had been and remained in substantially
continuous operation for a period in excess of thirty days and
had gross revenues of $2,000 in a single day.

(Title 18, United States Code, Sections 1955 and 2.)

COUNT THIRTY

(Conspiracy To Operate An Illegal Numbers Business –
Genovese Organized Crime Family)

The Grand Jury fur