. U-J

witnesses.
The individual members of the enterprise used their
membership in and association with the Patriarca Family and the
Winter Hill Gang to facilitate and to carry out their unlawful
activities.
THE RACKETEERING CONSPIRACY
2. In or about and between approximately 1967 and January
1995, in the District of Massachusetts and elsewhere, the·
defendants
FRANCIS P. SALEMME,
JAMES J. BULGER,
STEPHEN J. FLEMMI,
ROBERT P. DELUCA, and
JAMES M. MARTORANO,
and others, known and unknown to the Grand Jury including John
Martorano, George Kaufman, and Francis P. Salemme, Jr., being
persons employed by and associated with the enterprise described
in paragraph l(k) of this Count, did unlawfully, willfully, and
knowingly conspire, combine, confederate, and agree together with
each other and with other persons known and unknown to the grand
jury, to conduct and to participate, directly and indirectly, in
the cond~ct
of the affairs of the enterprise, which was engaged
in and the activities of which affected interstate and foreign
commerce, through a pattern of racketeering activity as set forth
in paragraphs Twenty-four through Sixty-two of this Count and
through the collection of unlawful debt as set forth in paragraph
Sixty-three, in violation of Title 18, united states Code,
section 1962(d).
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