LAS VEGAS - - A local "strip club" manager has been indicted on federal racketeering and tax charges, and for making false statements to the Grand Jury, announced Daniel G. Bogden, United States Attorney for the District of Nevada, Ellen B. Knowlton, Special Agent-in-Charge of the FBI for Nevada, Erick Martinez, Special Agent-in-Charge of IRS Criminal Investigation for Nevada, and Clark County Sheriff Bill Young of the Las Vegas Metropolitan Police Department.

In an Indictment returned yesterday and unsealed today, ROBERT D'APICE, age 50, of Las Vegas, is charged with one count of Participating in an Enterprise Through a Pattern of Racketeering Activity and four counts of False Statement Before Grand Jury. A co-defendant, PAULA MCBRIDE, age 27, of Henderson, is charged with two counts of False Statement Before Grand Jury. A second Indictment, returned January 11, 2005, and unsealed today, charges D'APICE and NICOLE LEE RUBINO, of Las Vegas, with Tax Evasion.

If convicted, D'APICE is facing up to 20 years in prison and a $250,000 fine on the racketeering charges, and D'APICE, MCBRIDE, and RUBINO face up to five years in prison and a $250,000 fine on each of the false statements and the tax evasion charges.

According to the racketeering Indictment, The Power Company, Inc., doing business as The Crazy Horse Too (hereinafter, the Crazy Horse) a "gentleman's club" or "strip club" in Las Vegas, constituted a racketeering "enterprise" as defined under federal racketeering statutes.

The Indictment alleges that from approximately 1997, ROBERT D'APICE, worked as a shift manager at the Crazy Horse. Patrons of the Crazy Horse paid dancers to perform semi-nude or topless dances for them. Up to 400 dancers worked a particular shift at the Crazy Horse, earning $100 to $2,000 per shift. Dancers collected payments from the patrons, and were required to pay 15 percent of their earnings to the business. If a patron refused to pay a dancer, or if a patron disputed charges claimed by a dancer, dancers contacted the shift manager or other male employees at the Crazy Horse.

Depending on the patron and other circumstances, the shift manager or other male employees allegedly sought to extort or rob payment from patrons through either threats of violence or actual violence. The shift manager and other male employees also allegedly intimidated patrons and committed acts of violence against them in order to promote an atmosphere of fear and respect and to discourage the patrons from disputing charges or questioning management.

The Indictment alleges that D'APICE committed the following racketeering acts:

On or about September 20, 2001, extortion and robbery against K.H.;

On or about January 28, 2001, extortion, robbery and kidnaping against B.K. and B.L.;

On or about December 29, 2000, extortion and robbery against R.N.;

On or about August 14, 2000, extortion and robbery against J.B.;

On or about April 4, 2000, extortion and robbery against A.S.

The Indictment further states that from about August 2001 to present, Special Federal Grand Juries for the District of Nevada have been investigating the activities of D'APICE, the Crazy Horse, and its associates concerning possible violations of federal racketeering, fraud, illegal sexual activity, and drug statutes. The investigation includes D'APICE'S alleged use of extortion to collect monies from patrons, using women from outside Nevada to engage in prostitution, and the distribution of narcotics inside the CRAZY HORSE.

The Indictment alleges that D'APICE testified falsely under oath before the Special Grand Jury on January 28, 2003. It alleges that D'APICE denied touching or assaulting Henry in front of the Crazy Horse on September 20, 2001; denied detaining, threatening, and intimidating customers to get them to pay their disputed charges; and denied having more than two physical altercations with patrons of the Crazy Horse during his employment there, knowing that these statements were false.

The Indictment also alleges that on August 27, 2002, PAULA McBRIDE, a former cocktail waitress at the Crazy Horse, testified falsely under oath before the Special Grand Jury by stating that she had not observed victim Kirk Henry exit the Crazy Horse with D'APICE on September 20, 2001, and by denying that she had reported to FBI Agents on August 20, 2002, that she had seen D'APICE near Kirk Henry on September 20, 2001.

The tax evasion indictment alleges that from approximately April 15, 1997, through December 2004, ROBERT D'APICE and NICOLE LEE RUBINO willfully attempted to evade and defeat the payment of at least $40,000 in taxes owed by D'APICE for the calendar years 1996 through 2002, by titling assets in the names of nominees; filing false individual income tax returns; providing false financial information to the IRS; and frequently using cash to make purchases and pay expenses.

D'APICE and McBRIDE were arrested without incident today, and an arrest warrant is pending for defendant RUBINO. All three will be scheduled for initial appearance hearings and arraignments in the immediate future before U.S. Magistrate Judge Johnston.

This case is being investigated by Special Agents with the FBI and IRS Criminal Investigation and Officers/Detectives with the Las Vegas Metropolitan Police Department, and is being prosecuted by Assistant United States Attorneys Eric Johnson and Timothy Vasquez.

The public is reminded that an indictment contains only charges and is not evidence of guilt. The defendants are presumed innocent and entitled to a fair trial at which the government has the burden of proving guilt beyond a reasonable doubt.

# # # #