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Indictment of Squitieri et al - Combined Counties Police Association

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delivered by mail according to the direction thereon, and at the<br />

place at which it was directed to be delivered by the person to<br />

whom it was addressed, to wit, DEPALMA, NORDONE, and others filed<br />

an insurance claim with State Farm Insurance Company f<strong>al</strong>sely<br />

stating that a 2004 Ford Thunderbird had been stolen, during the<br />

course <strong>of</strong> which scheme State Farm caused mailings to be made to<br />

the person who filed the claim, in violation <strong>of</strong> Title 18, United<br />

States Code, Sections 1341 and 2.<br />

Rack<strong>et</strong>eering Act Twenty-Two – Trafficking<br />

In Items Bearing Counterfeit Marks<br />

36. From in or about September 2003, up to and<br />

including in or about March 2005, in the Southern District <strong>of</strong> New<br />

York and elsewhere, GREGORY DEPALMA, the defendant, and others<br />

known and unknown, unlawfully, intention<strong>al</strong>ly, and knowingly<br />

trafficked, and attempted to traffic, in goods and used<br />

counterfeit marks on and in connection with such goods, to wit,<br />

GREGORY DEPALMA and others distributed merchandise bearing<br />

counterfeit trademarked designs, in violation <strong>of</strong> Title 18, United<br />

States Code, Sections 2320 and 2.<br />

(Title 18, United States Code, Section 1962(c).)<br />

46

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