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Indictment of Squitieri et al - Combined Counties Police Association

Indictment of Squitieri et al - Combined Counties Police Association

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with the consent <strong>of</strong> other persons, to wit, the employees,<br />

contractors, and agents <strong>of</strong> a New York City radio station, which<br />

consent would have been and was induced by the wrongful use <strong>of</strong><br />

actu<strong>al</strong> and threatened force, violence, and fear, and thereby<br />

would and did obstruct, delay, and affect commerce and the<br />

movement <strong>of</strong> articles and commodities in commerce, as that term is<br />

defined in Title 18, United States Code, Section 1951(b)(3), in<br />

violation <strong>of</strong> Title 18, United States Code, Section 1951.<br />

b. From in or about July 2003, up through and<br />

including in or about October 2003, in the Southern District <strong>of</strong><br />

New York and elsewhere, ANTHONY MEGALE, a/k/a “Mac,” a/k/a<br />

“Machiavelli,” GREGORY DEPALMA, ROBERT VACCARO, and LOUIS<br />

FILIPPELLI, the defendants, and others known and unknown,<br />

unlawfully, willfully, and knowingly did commit extortion, as<br />

that term is defined in Title 18, United States Code, Section<br />

1951(b)(2), by obtaining property from and with the consent <strong>of</strong><br />

others, to wit, the employees, contractors and agents <strong>of</strong> a New<br />

York City radio station, which consent was induced by the<br />

wrongful use <strong>of</strong> actu<strong>al</strong> and threatened force, violence, and fear,<br />

and thereby did obstruct, delay, and affect commerce and the<br />

movement <strong>of</strong> articles and commodities in commerce, as that term is<br />

defined in Title 18, United States Code, Section 1951(b)(3), in<br />

violation <strong>of</strong> Title 18, United States Code, Sections 1951 and 2.<br />

28

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