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 further charges:

1. From in or about the 1990s, up through and
   including in or about March 2005, in the Southern District of New
   York and elsewhere, while PASQUALE DELUCA, a/k/a “Scop,” the
   defendant, was on release pursuant to an order of the United
   States District Court for the Southern District of New York,
   dated on or about February 26, 2003, issued pursuant to Title 18,
   United States Code, Section 3142(c), DELUCA, and others known and
   unknown, through DELUCA’s membership in the Genovese Organized
   Crime Family of LCN, 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 PASQUALE DELUCA, a/k/a “Scop,”, the defendant, and others
   known and unknown, 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.
   

2. Overt Acts
   
2. In furtherance of said conspiracy and to effect
   the illegal object thereof, the following overt act, among
   others, was committed:
   

a. On or about September 13, 2004, PASQUALE
DELUCA, a/k/a “Scop,” met GREGORY DEPALMA at a location in
Westchester County, New York.

(Title 18, United States Code, Sections 371 and 3147(1).)

COUNT THIRTY-ONE

(Conspiracy To Collect An Extension
Of Credit By Extortionate Means)

The Grand Jury further charges:

73. From in or about February 2004, up through andincluding in or about October 2004, in the Southern District ofNew York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, JOHNCAPRA, a/k/a “Johnny Hooks,” JOSEPH FORNINO, a/k/a “Joey PerVoi,” AL ALVAREZ, and MARK DENUZIO, the defendants, and othersknown and unknown, through CAPRA’s position as a Capo in theLuchese Organized Crime Family of LCN, unlawfully, willfully, andknowingly combined, conspired, confederated, and agreed togetherand with each other to participate in the use of extortionatemeans to collect and attempt to collect extensions of credit, asthat term is defined in Title 18, United States Code, Section891, and to punish a person for the nonrepayment of saidextensions of credit, to wit, DEPALMA, VACCARO, CAPRA, FORNINO,ALVAREZ, DENUZIO, and others agreed to, and did, threatenphysical violence and other harm if Victim #2 did not make promptrepayment of various loans and other debts.

(Title 18, United States Code, Section 894.)

COUNT THIRTY-TWO

(Collection Of Extensions Of
Credit By Extortionate Means)

The Grand Jury further charges:

74. From in or about February 2004, up through and
including in or about October 2004, in the Southern District of
New York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, JOHN
CAPRA, a/k/a “Johnny Hooks,” JOSEPH FORNINO, a/k/a “Joey Per
Voi,” AL ALVAREZ, and MARK DENUZIO, the defendants, and others
known and unknown, through CAPRA’s position as a Capo in the
Luchese Organized Crime Family of LCN, unlawfully, willfully, and
knowingly used extortionate means to collect and attempt to
collect extensions of credit as that term is defined in Title 18,
United States Code, Section 891, and to punish a person for the
nonrepayment of such extensions of credit, to wit, DEPALMA,
VACCARO, CAPRA, FORNINO, ALVAREZ, DENUZIO, and others threatened
Victim #2 with physical violence and other harm if he did not
make prompt repayment of various loans and other debts.

(Title 18, United States Code, Sections 894 and 2.)

COUNT THIRTY-THREE

(Loansharking)
The Grand Jury further charges:

75. From in or about October 2003, up through and
including in or about August 2004, in the Southern District of

New York and elsewhere, GREGORY DEPALMA, the defendant, and

others known and unknown, unlawfully, willfully, and knowingly
made an extortionate extension of credit, as that term is defined
in Title 18, United States Code, Section 891, to wit, a loan of
$10,000, to Robert Sanseverino, a/k/a “Bobby Phones.”

(Title 18, United States Code, Sections 891, 892 and 2.)

COUNT THIRTY-FOUR

(Conspiracy To Transport And Receive
Stolen Property - Watches And Jewelry)

The Grand Jury further charges:

1. From in or about December 2003, up through and
   including in or about March 2005, in the Southern District of New
   York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, ROBERT
   PERSICO, and THOMAS D’AGOSTINO, a/k/a “Tommy 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 an offense against the United
   States, to wit, to violate Title 18, United States Code, Sections
   2314 and 2315.
   

1. It was a part and an object of the conspiracy that
   GREGORY DEPALMA, ROBERT VACCARO, ROBERT PERSICO, and THOMAS
   D’AGOSTINO, a/k/a “Tommy D,” the defendants, and others known and
   unknown, unlawfully, willfully and knowingly would and did
   transport, transmit and transfer in interstate commerce, goods,
   wares and merchandise, to wit, assorted watches and jewelry,
   having a value in excess of $5,000, which the defendants believed
   

2. had been stolen, converted and taken by fraud, in violation of
   Title 18, United States Code, Sections 2314 and 21.
   
1. It was a further part and an object of the
   conspiracy that GREGORY DEPALMA, ROBERT VACCARO, ROBERT PERSICO,
   and THOMAS D’AGOSTINO, a/k/a “Tommy D,” the defendants,
   unlawfully, willfully and knowingly would and did receive,
   possess, conceal, store, barter, sell, and dispose of goods,
   wares, and merchandise, namely assorted watches and jewelry,
   having a value in excess of $5,000, which the defendants believed
   had crossed a State boundary, after being stolen, unlawfully
   converted, and taken, believing the same to have been stolen,
   unlawfully converted, and taken, in violation of Title 18, United
   States Code, Sections 2315 and 21.
   

2. Overt Acts
   
2. In furtherance of said conspiracy and to effect
   the illegal objects thereof, the following overt acts, among
   others, were committed:
   

a.

On or about October 31, 2003, GREGORY DEPALMA
met another individual (“Individual #2") at a location in
Westchester County, New York, and received eleven pieces of
jewelry.

b.

On or about November 3, 2003, GREGORY DEPALMA
met Individual #2 in Westchester County, New York.

c.

On or about December 13, 2003, GREGORY
DEPALMA and THOMAS D’AGOSTINO had a telephone conversation.

d.

On or about February 10, 2004, GREGORY
DEPALMA and ROBERT PERSICO met in New Rochelle, New York.

e.

On or about March 12, 2004, GREGORY DEPALMA
and ROBERT PERSICO met in New Rochelle, New York.

f.

On or about July 29, 2004, GREGORY DEPALMA
and ROBERT VACCARO met in New Rochelle, New York.

g.

On or about August 13, 2004, GREGORY DEPALMA,
ROBERT VACCARO, and Individual #2 had a meeting at a restaurant
in New Rochelle, New York.

(Title 18, United States Code, Section 371.)

COUNT THIRTY-FIVE

(Interstate Transportation Of Stolen
Property - Watches And Jewelry)

The Grand Jury further charges:

80. From in or about May 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, ROBERT
PERSICO, and THOMAS D’AGOSTINO, a/k/a “Tommy D,” the defendants,
and others known and unknown, unlawfully, willfully and knowingly
did transport, transmit, and transfer in interstate commerce,
goods, wares and merchandise, to wit, assorted watches and
jewelry, having a value in excess of $5,000, which the defendants
believed had been stolen, converted and taken by fraud.

(Title 18, United States Code, Sections 2314, 21 and 2.)

COUNT THIRTY-SIX

(Receipt Of Stolen Property - Watches And Jewelry)

The Grand Jury further charges:

81. From in or about May 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, ROBERT
PERSICO, THOMAS D’AGOSTINO, a/k/a “Tommy D,” the defendants, and
others known and unknown, unlawfully, willfully and knowingly did
receive, possess, conceal, store, barter, sell, and dispose of
goods, wares and merchandise, namely, assorted watches and
jewelry, having a value in excess of $5,000, which the defendants
believed had crossed a State boundary after being stolen,
unlawfully converted, and taken, believing the same to have been
stolen, unlawfully converted, and taken.

(Title 18, United States Code, Sections 2315, 21, and 2.)

COUNT THIRTY-SEVEN

(Conspiracy To Transport And Receive
Stolen Property - Televisions)

The Grand Jury further charges:

1. From in or about January 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, ROBERT VACCARO, JOSEPH FORNINO,
   

2. a/k/a “Joey Per Voi,” and ROBERT VACCARO, JR., 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, Sections
   2314 and 2315.
   
1. It was a part and an object of the 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, ROBERT VACCARO, JOSEPH FORNINO, a/k/a “Joey Per Voi,”
   and ROBERT VACCARO, JR., the defendants, and others known and
   unknown, unlawfully, willfully and knowingly would and did
   transport, transmit and transfer in interstate and foreign
   commerce, goods, wares and merchandise, to wit, flat screen
   televisions, each having a value in excess of $5,000, which the
   defendants believed had been stolen, converted and taken by
   fraud, in violation of Title 18, United States Code, Section
   2314.
   

2. It was a further part and an object of the
   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, ROBERT VACCARO, JOSEPH FORNINO,
   a/k/a “Joey Per Voi,” and ROBERT VACCARO, JR., the defendants,
   unlawfully, willfully and knowingly would and did receive,
   

possess, conceal, store, barter, sell, and dispose of goods,
wares, and merchandise, namely flat screen televisions, having a
value in excess of $5,000, which the defendants believed had
crossed a State boundary, after being stolen, unlawfully
converted, and taken, believing the same to have been stolen,
unlawfully converted, and taken, in violation of Title 18, United
States Code, Section 2315.

Overt Acts

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

a.

On or about February 4, 2004, GREGORY DEPALMA
had a telephone conversation with JOSEPH FORNINO.

b.

On or about February 5, 2004, GREGORY DEPALMA
caused a flat screen television to be delivered to ANTHONY
MEGALE’s home in Connecticut.

c.

On or about March 3, 2004, GREGORY DEPALMA
had a telephone conversation with ROBERT VACCARO.

d.

On or about March 9, 2004, GREGORY DEPALMA
caused a flat screen television to be delivered to a location in
the Bronx, New York, so that it could be transported to ARNOLD
SQUITIERI’s home in New Jersey.

e.

On or about September 27, 2004, Individual
#2 met ROBERT VACCARO and ROBERT VACCARO, JR. at a location in

Westchester County, New York, and delivered a flat screen
television to ROBERT VACCARO, JR.
(Title 18, United States Code, Section 371.)

COUNT THIRTY-EIGHT

(Interstate Transportation Of Stolen
Property - Televisions)

The Grand Jury further charges:

86. From in or about January 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, ROBERT VACCARO, JOSEPH FORNINO,
and ROBERT VACCARO, JR., the defendants, and others known and
unknown, unlawfully, willfully, and knowingly did transport,
transmit, and transfer, in interstate and foreign commerce,
goods, wares, and merchandise, having a value in excess of
$5,000, to wit, flat-screen televisions, which the defendants
believed had been stolen, converted and taken by fraud.

(Title 18, United States Code, Sections 2314, 21 and 2.)

COUNT THIRTY-NINE

(Receipt Of Stolen Property - Televisions)
The Grand Jury further charges:

87. From in or about January 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, ROBERT VACCARO, JOSEPH FORNINO,
and ROBERT VACCARO, JR., the defendants, and others known and
unknown, unlawfully, willfully and knowingly did receive,
possess, conceal, store, barter, sell, and dispose of goods,
wares and merchandise, namely, flat-screen televisions, having a
value in excess of $5,000, which the defendants believed had
crossed a State boundary after being stolen, unlawfully
converted, and taken, believing the same to have been stolen,
unlawfully converted, and taken.

(Title 18, United States Code, Sections 2315, 21 and 2.)

COUNT FORTY

(Conspiracy To Transport And
Receive Stolen Automobiles)

The Grand Jury further charges:

1. From in or about September 2003, up through and
   including in or about February 2004, in the Southern District of
   New York and elsewhere, GREGORY DEPALMA, ROBERT PERSICO, SAM
   NORDONE, and MICHAEL DEPALMA, 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, Sections 2312 and 2313.
   

1. It was a part and an object of the conspiracy that
   GREGORY DEPALMA, SAM NORDONE, ROBERT PERSICO, and MICHAEL
   

2. DEPALMA, the defendants, and others known and unknown,
   unlawfully, willfully and knowingly would and did transport in
   interstate commerce motor vehicles, to wit, BMW and Cadillac
   automobiles transported from New York to Ohio, which the
   defendants knew had been stolen, in violation of Title 18, United
   States Code, Section 2312.
   
1. It was a further part and an object of the
   conspiracy that GREGORY DEPALMA, SAM NORDONE, ROBERT PERSICO, and
   MICHAEL DEPALMA, the defendants, unlawfully, willfully and
   knowingly would and did receive, possess, conceal, store, barter,
   sell, and dispose of a motor vehicle, to wit, BMW and Cadillac
   automobiles, which had crossed a State boundary, after being
   stolen, knowing the same to have been stolen, in violation of
   Title 18, United States Code, Section 2313.
   

2. Overt Acts
   
2. In furtherance of said conspiracy and to effect
   the illegal objects thereof, the following overt acts, among
   others, were committed:
   

a.

On or about October 28, 2003, GREGORY DEPALMA
had a telephone conversation with SAM NORDONE.

b.

On or about January 10, 2004, GREGORY DEPALMA
had a telephone conversation with MICHAEL DEPALMA.

c.

On or about January 12, 2004, GREGORY DEPALMA
had a telephone conversation with ROBERT PERSICO.

d. On or about February 2, 2005, GREGORY DEPALMA

had a conversation with SAM NORDONE.
(Title 18, United States Code, Section 371.)
COUNT FORTY-ONE
(Interstate Transportation Of Stolen Automobiles)
The Grand Jury further charges:

92. From in or about October 2003, up through and
including in or about February 2004, in the Southern District of
New York and elsewhere, GREGORY DEPALMA, ROBERT PERSICO, SAM
NORDONE, and MICHAEL DEPALMA, the defendants, and others known
and unknown, unlawfully, willfully, and knowingly did transport
in interstate commerce motor vehicles, including BMW and Cadillac
automobiles, knowing the same to have been stolen.

(Title 18, United States Code, Sections 2312 and 2.)

COUNT FORTY-TWO

(Receipt Of Stolen Automobiles)
The Grand Jury further charges:

93. From in or about October 2003, up through and
including in or about February 2004, in the Southern District of
New York and elsewhere, GREGORY DEPALMA, ROBERT PERSICO, SAM
NORDONE, and MICHAEL DEPALMA, the defendants, and others known
and unknown, unlawfully, willfully and knowingly received,
possessed, concealed, stored, bartered, sold, and disposed of
motor vehicles, including BMW and Cadillac automobiles, which had

crossed a State boundary after being stolen, knowing the same to
have been stolen.
(Title 18, United States Code, Sections 2313 and 2.)

COUNT FORTY-THREE

(Conspiracy To Operate High-Stakes Super Bowl Pools)
The Grand Jury further charges:

1. From in or about December 2003, up through and
   including in or about February 2005, in the Southern District of
   New York and elsewhere, GREGORY DEPALMA, JOSEPH FORNINO, a/k/a
   “Joey Per Voi,” and JUSTIN CARTISANO, 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.
   

2. It was a part and an object of said conspiracy
   that GREGORY DEPALMA, JOSEPH FORNINO, a/k/a “Joey Per Voi,” and
   JUSTIN CARTISANO, the defendants, and others known and unknown,
   would and did conduct, finance, manage, supervise, direct, and
   own all and part of an illegal gambling business, namely, high-
   stakes Super Bowl betting pools conducted at various commercial
   establishments, which grossed in excess of approximately
   $150,000, 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 remained in
substantially continuous operation for a period in excess of
thirty days and had gross revenues of $2,000 in a single day, in
violation of Title 18, United States Code, Section 1955.

Overt Acts

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

a.

On or about January 9, 2004, GREGORY DEPALMA
and JUSTIN CARTISANO spoke on the telephone.

b.

On or about January 25, 2004, GREGORY DEPALMA
and JOSEPH FORNINO spoke on the telephone.

c. On or about January 18, 2005, GREGORY DEPALMA

and Frank D’Agostino spoke on the telephone.
(Title 18, United States Code, Section 371.)

COUNT FORTY-FOUR

(Operation Of High-Stakes Super Bowl Pools)
The Grand Jury further charges:

97. From at least in or about December 2003, up
through and including in or about February 2005, in the Southern
District of New York and elsewhere, GREGORY DEPALMA, JOSEPH
FORNINO, a/k/a “Joey Per Voi,” and JUSTIN CARTISANO, 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,
high-stakes Super Bowl betting pools conducted at various
commercial establishments, which grossed in excess of
approximately $150,000, 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 FORTY-FIVE

(Use Of A Wire Facility In
Furtherance Of A Gambling Operation)

The Grand Jury further charges:

98. From in or about October 2004, up through and
including in or about December 2004, in the Southern District of
New York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, and JOHN
VACCARO, a/k/a “Popcorn,” the defendants, and others known and
unknown, being engaged in the business of betting and wagering,
unlawfully, willfully, and knowingly did use a wire communication
facility, namely the telephone assigned (866) 888-6555, for the
transmission in interstate and foreign commerce of bets, wagers,
and information assisting in the placing of bets and wagers on
sporting events and contests, and for the transmission of wire

communications which did entitle the recipient to receive money
and credit as a result of bets and wagers, and for information
assisting in the placing of bets and wagers.

(Title 18, United States Code, Sections 1084 and 2.)

COUNT FORTY-SIX

(Conspiracy To Embezzle From A Union Benefit Plan)
The Grand Jury further charges:

99. From in or about April 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, ROBERT
VACCARO, JR., JAMES VETRANO, and JOSEPH MORAY, 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

664.

100. It was a part and an object of the conspiracy that
GREGORY DEPALMA, ROBERT VACCARO, ROBERT VACCARO, JR., JAMES
VETRANO, and JOSEPH MORAY, the defendants, and others known and
unknown, would and did embezzle, steal, abstract, and convert to
their own use, and to the use of another, moneys, funds,
securities, premiums, credits, property, and other assets of an
employee welfare benefit plan and employee pension benefit plan,
as that term is defined in Title 18, United States Code, Section

664, and of a fund connected therewith, namely, employer
contributions owed to the pension, health and insurance benefit
funds of Local 305, in violation of Title 18, United States Code,
Section 664.

Overt Acts

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

a. On or about May 21, 2003, GREGORY DEPALMA,
JAMES VETRANO, the president of Local 305, JOSEPH MORAY and
others met at a location in Westchester County, New York.

b. On or about March 17, 2004, GREGORY DEPALMA

and ROBERT VACCARO met at a restaurant in Tuckahoe, New York.
(Title 18, United States Code, Section 371.)

COUNT FORTY-SEVEN

(Union Embezzlement)
The Grand Jury further charges:

102. From in or about April 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, ROBERT
VACCARO, JR., JAMES VETRANO and JOSEPH MORAY, the defendants, and
others known and unknown, unlawfully, willfully, and knowingly
embezzled, stole, abstracted, and converted to their own use, and
to the use of another, moneys, funds, securities, premiums,

credits, property, and other assets of an employee welfare
benefit plan and employee pension benefit plan, as that term is
defined in Title 18, United States Code, Section 664, and of a
fund connected therewith, namely, employer contributions owed to
the pension, health and insurance benefit funds of Local 305.

(Title 18, United States Code, Sections 664 and 2.)

COUNT FORTY-EIGHT

(Conspiracy To Commit Mail Fraud)
The Grand Jury further charges:

1. From in or about April 2003, up through and
   including in or about March 2005, in the Southern District of New
   York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, ROBERT
   VACCARO, JR., JAMES VETRANO, and JOSEPH MORAY, the defendants,
   and others known and unknown, unlawfully, willfully and knowingly
   did combine, conspire, confederate and agree together and with
   each other to violate Title 18, United States Code, Section 1341.
   

2. It was a part and an object of the conspiracy that
   GREGORY DEPALMA, ROBERT VACCARO, ROBERT VACCARO, JR., JAMES
   VETRANO, and JOSEPH MORAY, the defendants, and others known and
   unknown, unlawfully, willfully and knowingly, having devised and
   intending to devise a scheme and artifice to defraud, and for
   obtaining money and property by means of false and fraudulent
   pretenses, representations and promises, for the purpose of
   executing such scheme and artifice and attempting so to do, would
   

and did place in a post office and authorized depository for mail
matter, a matter and thing to be sent and delivered by the Postal
Service, and would and did deposit and cause to be deposited a
matter and thing to be sent and delivered by a private and
commercial interstate carrier, and would and did take and receive
therefrom, such matter and thing, and would and did cause to be
delivered by mail and such carrier according to the direction
thereon, and at the place at which it was directed to be
delivered by the person to whom it was addressed, such matter and
thing, in violation of Title 18, United States Code, Section
1341.

Overt Acts

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

a. On or about May 21, 2003, GREGORY DEPALMA,
JAMES VETRANO, the president of Local 305, JOSEPH MORAY and
others met at a location in Westchester County, New York.

b. On or about March 17, 2004, GREGORY DEPALMA

and ROBERT VACCARO met at a restaurant in Tuckahoe, New York.
(Title 18, United States Code, Section 1349.)

COUNT FORTY-NINE

(Mail Fraud)
The Grand Jury further charges:

106. From in or about April 2003, up through and
including in or about March 2005, in the Southern District of New
York and elsewhere, GREGORY DEPALMA, ROBERT VACCARO, ROBERT
VACCARO, JR., JAMES VETRANO, and JOSEPH MORAY, the defendants,
and others known and unknown, unlawfully, willfully, and
knowingly, having devised and intending to devise a scheme and
artifice to defraud, and for obtaining money and property by
means of false and fraudulent pretenses, representations, and
promises, for the purpose of executing such scheme and artifice
and attempting to do so, did place in a post office and
authorized depository for mail matter a matter and thing to be
sent and delivered by the United States Postal Service, and did
take and receive therefrom, such matter and thing, and did cause
such matter and thing to be delivered by mail according to the
direction thereon, and at the place at which it was directed to
be delivered by the person to whom it was addressed, to wit, the
defendants and others fraudulently obtained medical benefits from
Local 305 by falsely claiming to be employed by an employer who
had entered into a collective bargaining agreement with Local

305, during the course of which scheme Local 305 mailed
statements and other information to the defendants.
(Title 18, United States Code, Sections 1341 and 2.)

COUNT FIFTY

(Conspiracy To Commit Mail Fraud –
Staged Theft Of A Ford Thunderbird)

The Grand Jury further charges:

1. From in or about May 2004, up to and including in
   or about July 2004, in the Southern District of New York and
   elsewhere, GREGORY DEPALMA, SAM NORDONE, and JUSTIN CARTISANO,
   the defendants, and others known and unknown, unlawfully,
   willfully and knowingly did combine, conspire, confederate and
   agree together and with each other to violate Title 18, United
   States Code, Section 1341.
   

2. It was a part and an object of the conspiracy that
   GREGORY DEPALMA, SAM NORDONE, and JUSTIN CARTISANO, the
   defendants, and others known and unknown, unlawfully, willfully
   and knowingly, having devised and intending to devise a scheme
   and artifice to defraud, and for obtaining money and property by
   means of false and fraudulent pretenses, representations and
   promises, for the purpose of executing such scheme and artifice
   and attempting so to do, would and did place in a post office and
   authorized depository for mail matter, a matter and thing to be
   sent and delivered by the Postal Service, and would and did
   deposit and cause to be deposited a matter and thing to be sent
   

and delivered by a private and commercial interstate carrier, and
would and did take and receive therefrom, such matter and thing,
and would and did cause to be delivered by mail and such carrier
according to the direction thereon, and at the place at which it
was directed to be delivered by the person to whom it was
addressed, such matter and thing, in violation of Title 18,
United States Code, Section 1341.

Overt Acts

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

a.

On or about May 21, 2004, SAM NORDONE drove a
2004 Ford Thunderbird automobile to a location in the Bronx, New
York.

b.

On or about June 7, 2004, GREGORY DEPALMA had
a telephone conversation with JUSTIN CARTISANO regarding
CARTISANO’s filing of an insurance claim falsely stating that the
2004 Ford Thunderbird had been stolen from outside SAM NORDONE’s
house.

(Title 18, United States Code, Section 1349.)

COUNT FIFTY-ONE

(Mail Fraud)
The Grand Jury further charges:

110. From in or about May 2004, up to and including in
or about July 2004, in the Southern District of New York and
elsewhere, GREGORY DEPALMA, SAM NORDONE, and JUSTIN CARTISANO,
the defendants, and others known and unknown, unlawfully,
willfully, and knowingly, having devised and intending to devise
a scheme and artifice to defraud, and for obtaining money and
property by means of false and fraudulent pretenses,
representations, and promises, for the purpose of executing such
scheme and artifice and attempting to do so, did place in a post
office and authorized depository for mail matter a matter and
thing to be sent and delivered by the United States Postal
Service, and did take and receive therefrom, such matter and
thing, and did cause such matter and thing to be delivered by
mail according to the direction thereon, and at the place at
which it was directed to be delivered by the person to whom it
was addressed, to wit, DEPALMA, NORDONE, CARTISANO, and others
filed an insurance claim with State Farm Insurance Company
falsely stating that a 2004 Ford Thunderbird had been stolen,
during the course of which scheme State Farm caused mailings to
be made to the person who filed the claim.

(Title 18, United States Code, Sections 1341 and 2.)

COUNT FIFTY-TWO

(Conspiracy To Traffic In Counterfeit Goods)
The Grand Jury further charges:

1. From in or about September 2003, up through and
   including in or about March 2005, in the Southern District of New
   York and elsewhere, GREGORY DEPALMA, ROBERT SANSEVERINO, a/k/a
   “Bobby Phones,” and ALFRED LAFATA, JR., 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, Sections 2320.
   

1. It was a part and an object of the conspiracy that
   GREGORY DEPALMA, ROBERT SANSEVERINO, a/k/a “Bobby Phones,” and
   ALFRED LAFATA, JR., the defendants, and others known and unknown,
   unlawfully, intentionally and knowingly would and did traffic in
   goods and use counterfeit marks on and in connection with such
   goods, to wit, DEPALMA, SANSEVERINO and LAFATA, Jr., and others,
   distributed merchandise, including watches and bags, bearing
   counterfeit trademarked designs of, among others, Rolex and Louis
   Vuitton, in violation of Title 18, United States Code, Section
   2320.
   

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

a.

On or about September 2, 2003, GREGORY
DEPALMA, ALFRED LAFATA, JR., and others, met at a location in
Westchester County, New York.

b.

On or about November 25, 2003, GREGORY
DEPALMA, ROBERT SANSEVERINO, and others, met at a location in

Westchester County, New York.
(Title 18, United States Code, Section 371.)

COUNT FIFTY-THREE

(Trafficking In Items Bearing Counterfeit Marks)

114. From in or about September 2003, up to and
including in or about March 2005, in the Southern District of New
York and elsewhere, GREGORY DEPALMA, ROBERT SANSEVERINO, a/k/a
“Bobby Phones,” and ALFRED LAFATA, JR., the defendants, and
others known and unknown, unlawfully, intentionally, and
knowingly trafficked, and attempted to traffic, in goods and used
counterfeit marks on and in connection with such goods, to wit,
DEPALMA, SANSEVERINO, and LAFATA, JR., and others distributed
merchandise, including designer watches and bags, bearing

counterfeit trademarked designs, including Rolex and Louis
Vuitton.

(Title 18, United States Code, Sections 2320 and 2.)

FIRST FORFEITURE ALLEGATION

115. The allegations contained in Counts One and Two of
this Indictment are repeated, realleged, and incorporated by
reference as though fully set forth herein for the purpose of
alleging forfeiture pursuant to the provisions of Title 18,
United States Code, Section 1963. Pursuant to Rule 32.2, Fed.

R. Crim. P., notice is hereby given to the defendants that the
United States will seek forfeiture as part of any sentence in
accordance with Title 18, United States Code, Section 1963 in the
event of any defendant’s conviction under Counts One and/or Two
of this Indictment.

116. The defendants, 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.,

i. have acquired and maintained interests in
violation of Title 18, United States Code, Section 1962, which

interests are subject to forfeiture to the United States pursuant
to Title 18, United States Code, Section 1963(a)(1);

ii. have an interest in, security of, claims against,
and property and contractual rights which afford a source of
influence over the enterprise named and described herein which
the defendants established, operated, controlled, conducted, and
participated in the conduct of, in violation of Title 18, United
States Code, Section 1962, which interests, securities, claims,
and rights are subject to forfeiture to the United States
pursuant to Title 18, United States Code, Section 1963(a)(2); and

iii. have property constituting and derived from
proceeds obtained, directly and indirectly, from the aforesaid
racketeering activity, in violation of Title 18, United States
Code, Section 1962, which property is subject to forfeiture to
the United States pursuant to Title 18, United States Code,
Section 1963(a)(3).

117. The interests of the defendants subject to
forfeiture to the United States pursuant to Title 18, United
States Code, Section 1963(a)(1), (a)(2), and (a)(3), include but
are not limited to:

a. at least $30 million in United States currency;

b. Any and all interest of JOSEPH FORNINO, the
defendant, in the real property and appurtenances, known as 23
North Main Street, Portchester, New York, including FORNINO’s

interest in the assets of the business operated thereon, the
Pasta Per Voi, a/k/a “Pasta Per Voi Italian Restaurant,” a/k/a
“Per Voi,” also including any gambling proceeds found therein;

c.

Any and all interest of SAM NORDONE, the
defendant, in the real property and appurtenances known as 2430
Boston Post Road, Larchmont, New York, including NORDONE’s
interest in the assets of the business operated thereon, Sam
Nordone & Sons Auto Body;

d.

Any and all interest of ARNOLD SQUITIERI, the
defendant, in a 42" SONY flat screen television, delivered to
SQUITIERI’s home in New Jersey on or about March 9, 2004;

e.

Any and all interest of ANTHONY MEGALE, the
defendant, in a 42" SONY flat screen television, delivered to
MEGALE’S home in Connecticut on or about February 5, 2004;

f.

Any and all interest of ROBERT VACCARO, JR. and
ROBERT VACCARO, the defendants, in a 42" Samsung flat screen
television, delivered to ROBERT VACCARO, JR. on or about
September 27, 2004;

g.

Any and all interest of GREGORY DEPALMA and SAM
NORDONE, the defendants, in one 2004 Ford Thunderbird, VIN#
1FAHP60A14Y109025, registered to Justin Cartisano;

h.

Any and all interest of GREGORY DEPALMA and SAM
NORDONE, the defendants, in one 2000 BMW, VIN# WBABM5346YJP00939;

i.

Any and all interest of GREGORY DEPALMA and SAM
NORDONE, the defendants, in one 1995 BMW, VIN# WBAEF6321SCC90304,
registered to Michael DePalma; and

j.

Any and all interest of GREGORY DEPALMA, SAM
NORDONE, and ROBERT PERSICO, the defendants, in one 1990 Cadillac
Fleetwood, VIN# 1G6CB5332L4348795;

k. Any and all interest of GREGORY DEPALMA, the

defendant, in one 2005 Chrysler 300, VIN# 2C3AA63H95H144644.
Substitute Assets

118. If any of the property described above as being
subject to forfeiture, as a result of any act or omission of the
defendants–

a.

cannot be located upon the exercise of
due diligence;

b.

has been transferred or sold to, or
deposited with, a third party;

c.

has been placed beyond the jurisdiction
of the court;

d.

has been substantially diminished in value; or

e.

has been commingled with other property

which cannot be divided without difficulty;
it is the intention of the United States, pursuant to Title 18,
United States Code, Section 1963(m), to seek forfeiture of any

other property of the defendant(s) up to the value of the
forfeitable property, including but not limited to:

a.

Any and all right, title, and interest held by LOUIS
FILIPPELLI, the defendant, in the real property and appurtenances
known as 13 Byram Brook Place, Armonk, New York;

b.

Any and all right, title, and interest held by
JOSEPH FORNINO, the defendant, in the real property and
appurtenances known as 4032-24th Street, Queens, New York;

c.

Any and all right, title, and interest held by
JOSEPH FORNINO, the defendant, in the real property and
appurtenances known as 131 Huntsbridge Road, Yonkers, New York
10704;

d.

Any and all right, title, and interest held by
NICHOLAS LASORSA, the defendant, in the real property and
appurtenances known as 15 Bonnie Briar Road, White Plains, New
York 10607;

e.

Any and all right, title, and interest held by
ANTHONY MEGALE, the defendant, in the real property and
appurtenances known as 105 Northwind Drive, Stamford, Connecticut
06903;

f.

Any and all right, title, and interest held by
ROBERT PERSICO, the defendant, in the real property and
appurtenances known as 75 Stoneleigh Road, Scarsdale, New York
10583;

g.

Any and all right, title, and interest held by
ROBERT PERSICO, the defendant, in the real property and
appurtenances known as 75 Woodford Road, Scarsdale, New York
10583;

h.

Any and all right, title, and interest held by
ROBERT PERSICO, the defendant, in the real property and
appurtenances known as 550 Franklin Avenue, Mount Vernon, New
York 10550;

i.

Any and all right, title, and interest held by SAM
NORDONE, the defendant, in the real property and appurtenances
known as 40 Mill River Road, South Salem, New York 12590;

j.

Any and all right, title, and interest held by SAM
NORDONE, the defendant, in the real property and appurtenances
known as 4 Hall Place, Eastchester, New York 10790;

k.

Any and all right, title, and interest held by
ALPHONSE SISCA, the defendant, in the real property and
appurtenances known as 53 Anderson Avenue, Englewood Cliffs, New
Jersey;

l.

Any and all right, title, and interest held by
ALPHONSE SISCA, the defendant, in the real property and
appurtenances known as 265 West 27^th Street, Ship Bottom, New
Jersey; and

m.

Any and all right, title, and interest held by
ARNOLD SQUITIERI, the defendant, in the real property and

appurtenances known as 42 Hickory Street, Englewood Cliffs, New
Jersey.

119. The above-named defendants, and each of them, are
jointly and severally liable for the forfeiture obligations
alleged above in Paragraph 117(a).

(Title 18, United States Code, Section 1963.)

SECOND FORFEITURE ALLEGATION

120. As the result of committing one or more of the
extortion, stolen property, loansharking, union embezzlement,
fraud or counterfeit goods offenses in violation of 18 U.S.C. §§
371, 664, 891, 892, 894, 1341, 1349, 1951, 2314, 2315 and 2320
alleged in Counts Four through Twenty-Seven, Thirty-One through
Thirty-Six through Forty-Two, Forty-Six through Forty-Nine, and
Fifty-Two through Fifty-Three of this Indictment, defendants
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,” THOMAS
CACCIOPOLI, a/k/a “Tommy Sneakers,” JOHN CAPRA, a/k/a “Johnny
Hooks,” CHRISTOPHER SUCARATO, JOSEPH FORNINO, a/k/a “Joey Per
Voi,” SAM NORDONE, ROBERT PERSICO, ROBERT VACCARO, JR., JAMES
VETRANO, MICHAEL DEPALMA, THOMAS D’AGOSTINO, a/k/a “Tommy D,”
FRANK D’AGOSTINO, a/k/a “Frankie D,” AL ALVAREZ, MARK DENUZIO,
JOSEPH MORAY, NEIL DELIETO, ROBERT SANSEVERINO, a/k/a “Bobby

Phones,” and ALFRED LAFATA, JR., the defendants, shall forfeit
to the United States pursuant to 18 U.S.C. § 981(a)(1)(C) and 28

U.S.C.

§ 2461, all property, real and personal, that constitutes
or is derived from proceeds traceable to the violations of 18

U.S.C.

§§ 371, 664, 891, 892, 894, 1343, 1349, 1951, 2314, 2315
and 2320, including but not limited to the following:

a.

At least $10,000,000 in United States currency,
for which the defendants are jointly and severally liable;

b.

Any and all interest of SAM NORDONE, the
defendant, in the real property and appurtenances known as 2430
Boston Post Road, Larchmont, New York, including NORDONE’s
interest in the assets of the business operated thereon, Sam
Nordone & Sons Auto Body;

c.

Any and all interest of GREGORY DEPALMA and SAM
NORDONE, the defendants, in one 2000 BMW, VIN# WBABM5346YJP00939;

d.

Any and all interest of GREGORY DEPALMA, SAM
NORDONE, and MICHAEL DEPALMA, the defendants, in one 1995 BMW,
VIN# WBAEF6321SCC90304 registered to MICHAEL DEPALMA; and

e.

Any and all interest of GREGORY DEPALMA, ROBERT
PERSICO, SAM NORDONE, and MICHAEL DEPALMA, the defendants, in one
1990 Cadillac Fleetwood, VIN# 1G6CB5332L4348795.

Substitute Assets

121. If any of the property described above as being subject
to forfeiture, as a result of any act or omission of the
defendant(s)–

a.

cannot be located upon the exercise of
due diligence;

b.

has been transferred or sold to, or
deposited with, a third party;

c.

has been placed beyond the jurisdiction
of the court;

d.

has been substantially diminished in value; or

e.

has been commingled with other property

which cannot be divided without difficulty;
it is the intention of the United States, pursuant to Title 21,
United States Code, Section 853(p), to seek forfeiture of any
other property of the defendant(s) up to the value of the
forfeitable property, including but not limited to:

a.

Any and all right, title, and interest held by LOUIS
FILIPPELLI, the defendant, in the real property and appurtenances
known as 13 Byram Brook Place, Armonk, New York;

b.

Any and all right, title, and interest held by
JOSEPH FORNINO, the defendant, in the real property and
appurtenances known as 4032-24th Street, Queens, New York;

c. Any and all right, title, and interest held by

JOSEPH FORNINO, the defendant, in the real property and
appurtenances known as 131 Huntsbridge Road, Yonkers, New York
10704;

d.

Any and all right, title, and interest held by
NICHOLAS LASORSA, the defendant, in the real property and
appurtenances known as 15 Bonnie Briar Road, White Plains, New
York 10607;

e.

Any and all right, title, and interest held by
ANTHONY MEGALE, the defendant, in the real property and
appurtenances known as 105 Northwind Drive, Stamford, Connecticut
06903;

f.

Any and all right, title, and interest held by
ROBERT PERSICO, the defendant, in the real property and
appurtenances known as 75 Stoneleigh Road, Yonkers, New York
10583;

g.

Any and all right, title, and interest held by
ROBERT PERSICO, the defendant, in the real property and
appurtenances known as 75 Woodford Road, Scarsdale, New York
10583;

h.

Any and all right, title, and interest held by
ROBERT PERSICO, the defendant, in the real property and
appurtenances known as 550 Franklin Avenue, Mount Vernon, New
York 10550;

i.

Any and all right, title, and interest held by SAM
NORDONE, the defendant, in the real property and appurtenances
known as 40 Mill River Road, South Salem, New York 12590;

j.

Any and all right, title, and interest held by SAM
NORDONE, the defendant, in the real property and appurtenances
known as 4 Hall Place, Eastchester, New York 10790;

k.

Any and all right, title, and interest held by
ARNOLD SQUITIERI, the defendant, in the real property and
appurtenances known as 42 Hickory Street, Englewood Cliffs, New
Jersey;

l.

Any and all right, title, and interest held by
ALPHONSE SISCA, the defendant, in the real property and
appurtenances known as 53 Anderson Avenue, Englewood Cliffs, New
Jersey;

m.

Any and all right, title, and interest held by
ALPHONSE SISCA, the defendant, in the real property and
appurtenances known as 265 West 27^th Street, Ship Bottom, New
Jersey;

n.

Any and all right, title, and interest held by JOHN
CAPRA, the defendant, in the real property and appurtenances
known as 18 Durie Avenue, Closter, New Jersey 07624;

o.

Any and all right, title, and interest held by
JOSEPH MORAY, the defendant, in the real property and
appurtenances known as 30 Valentine Street, Yonkers, New York;

p. Any and all right, title, and interest held by

JOSEPH MORAY, the defendant, in the real property and
appurtenances known as 110 Ash Street, Yonkers, New York 10701;
and

q. Any and all right, title, and interest held by
JAMES VETRANO, the defendant, in the real property and
appurtenances known as 120 Saw Mill River Road, Hastings-On-
Hudson, New York 10706, including VETRANO’s interest in the
assets of the business operated thereon, “120 Saw Mill River Road
Realty.”

(Title 18, United States Code, Sections 371, 664, 891,
892, 894, 1343, 1349, 1951, 2314, 2315 and 2320 and
Title 28, United States Code, Section 2461(c)).

THIRD FORFEITURE ALLEGATION

122. As the result of committing one or more of the
gambling offenses in violation of 18 U.S.C. §§ 371, 1084 and
1955, alleged in Counts Twenty-Eight through Thirty and Forty-
Three through Forty-Five of this Indictment, defendants 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, PASQUALE DELUCA, a/k/a “Scop,” JOSEPH
FORNINO, a/k/a “Joey Per Voi,” 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,” JUSTIN CARTISANO, and PAUL OLIVERI,
shall forfeit to the United States pursuant to 18 U.S.C. §§
981(a)(1)(C) and 1955(d) and 28 U.S.C. § 2461, any property,
including money used in the gambling offenses, and all property,
real and personal, that constitutes or is derived from proceeds
traceable to the violations of 18 U.S.C. §§ 371, 1084 and 1955,
including but not limited to the following:

a.

At least $20,000,000 in United States currency,
for which the defendants are jointly and severally liable;

b.

Any and all interest of JOSEPH FORNINO, in the
real property and appurtenances, known as 23 North Main Street,
Portchester, New York, including FORNINO’s interest in the assets
of the business operated thereon, the Pasta Per Voi a/k/a “Pasta
PerVoi Italian Restaurant,” a/k/a “Per Voi,” also including any
gambling proceeds found therein;

c.

Any and all interest of LEONARD MINUTO, SR. and
LEONARD MINUTO, JR., the defendants, in the real property and
appurtenances, known as 3046 Eastchester Road, Bronx, New York,
including any gambling proceeds found therein;

d.

Any and all interest of LEONARD MINUTO, SR. and
LEONARD MINUTO, JR., the defendants, in the real property and
appurtenances, at the unmarked entrance directly to the right of
the address known as 2952 Fenton Avenue, Bronx, New York,
including any gambling proceeds found therein; and

e. Any and all interest of LOUIS NATRELLA, the

defendant, in the real property and appurtenances, known as 744A
Morris Park Avenue, Bronx, New York, including any gambling
proceeds found therein.

Substitute Assets

123. If any of the property described above as being
subject to forfeiture, as a result of any act or omission of the
defendant(s)–

a.

cannot be located upon the exercise of
due diligence;

b.

has been transferred or sold to, or
deposited with, a third party;

c.

has been placed beyond the jurisdiction
of the court;

d.

has been substantially diminished in value; or

e.

has been commingled with other property

which cannot be divided without difficulty;
it is the intention of the United States, pursuant to Title 21,
United States Code, Section 853(p), to seek forfeiture of any
other property of the defendant(s) up to the value of the
forfeitable property, including but not limited to:

a.

Any and all right, title, and interest held by
LEONARD MINUTO, SR., the defendant, in the real property and
appurtenances known as 11 Norge Avenue, Nanuet, New York, 10954;

b.

Any and all right, title, and interest held by
LEONARD MINUTO, SR., the defendant, in the real property and
appurtenances known as 550 South Ocean Boulevard, #2204, Boca
Raton, Florida 33432;

c.

Any and all right, title, and interest held by
LEONARD MINUTO, JR, the defendant, in the real property and
appurtenances known as F5 Contempra Circle, Tappan, New York,
10983;

d.

Any and all right, title, and interest held by
PASQUALE DELUCA, the defendant, in the real property and
appurtenances known as 2940 East 194^th Street, Bronx, New York
10461;

e.

Any and all right, title, and interest held by LOUIS
FILIPPELLI, the defendant, in the real property and appurtenances
known as 13 Byram Brook Place, Armonk, New York;

f.

Any and all right, title, and interest held by
JOSEPH FORNINO, the defendant, in the real property and
appurtenances known as 4032-24th Street, Queens, New York;

g.

Any and all right, title, and interest held by
JOSEPH FORNINO, the defendant, in the real property and
appurtenances known as 131 Huntsbridge Road, Yonkers, New York
10704;

h.

Any and all right, title, and interest held by
ANTHONY MEGALE, the defendant, in the real property and

appurtenances known as 105 Northwind Drive, Stamford, Connecticut
06903;

i.

Any and all right, title, and interest held by
ALPHONSE SISCA, the defendant, in the real property and
appurtenances known as 53 Anderson Avenue, Englewood Cliffs, New
Jersey;

j.

Any and all right, title, and interest held by
ALPHONSE SISCA, the defendant, in the real property and
appurtenances known as 265 West 27^th Street, Ship Bottom, New
Jersey;

k.

Any and all right, title, and interest held by
ARNOLD SQUITIERI, the defendant, in the real property and
appurtenances known as 42 Hickory Street, Englewood Cliffs, New
Jersey;

l.

Any and all right, title, and interest held by PAUL
OLIVERI, the defendant, in the real property and appurtenances
known as 219 West Lovell Street, Mahopac, New York 10541; and

m.

Any and all right, title, and interest held by
ALFRED LAFATA, JR., the defendant, in the real property and
appurtenances known as 6 Vernon Drive, Scarsdale, New York 10583.

(Title 18, United States Code, Sections 371, 1084 and 1955
and Title 28, United States Code, Section 2461(c)).

FOREPERSON DAVID N. KELLEY
United States Attorney