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conduct his illegal activities. Yerardi also collected "rent" or extortion payments from other individuals engaged in illegal gambling activities on behalf of the Winter Hill Gang. Further, Yerardi's loansharking activities were financed, in part, by the winter Hill Gang. 12. It was part of the conspiracy that Peter J. Fiumara of Newton, Massachusetts 'owned and operated the squire Lounge, an adult entertainment club located ~n Revere, Massachusetts. Fiumara was also in the business of lending and collecting money in violation of sections 892 and 894 of Title 18 of the United states Code relating to extortionate credit transactions. Fiumara made "rent" or extortion payments to the defendant FRANCIS P. SALEMME and Francis P. Salemme, Jr. in order to conduct his illegal activities. Fiumara also interacted with Yerardi regarding certain mutual loansharking business. 13. It was part of the conspiracy that between 1978 and 1994 the winter Hill Gang collected "rent" or extortion payments from numerous bookmakers in the Greater Boston area. Among, these bookmakers were the following: Burton L. Krantz, Edward Lewis, James J. Katz, Thomas Ryan, Howard Levenson, Richard Brown, Bernard Weisman Mitchell Zukoff, and Joseph A. Yerardi, Jr. 14
14. It was part of the conspiracy that when the defendant FRANCIS P. SALEMME became the Boss of the Patriarca Family in approximately 1990, he sought to extend the conspiracy to collect extortion or "rent" payments into the Framingham, Massachusetts and Milford, Massachusetts areas. He was assisted in this activity by Francis P. Salemme, Jr., Patriarca Family associate Thomas Hillary, as well as Framingham bookmaker John "Jack" Snell and others known to the grand jury. It was also part of the conspiracy that at or about this time the defendant FRANCIS P. SALEMME also sought to extend the conspiracy to collect extortion or "rent" payments into the Lowell, Massachusetts area. He was assisted in this activity by the defendant ROBERT P. DELUCA and Patriarca Family associates Charles "Chucky" Flynn and Albert "Pancho" Gonsalves. 15. It was part of the'conspiracy that the defendant FRANCIS P. SALEMME also conspired with others including Francis P. Salemme, Jr. and Patriarca Family associates Thomas Hillary and Steven DiSa,rro to engage in illegal gambling activities by plaGing video poker machines in establishments such as bars and restaurants where the machines would be used in an illegal manner. 16. It was part of the conspiracy that the defendant FRANCIS P. SALEMME and Francis P. Salemme, Jr. sought to gain 15
Page 1 and 2: UNITED STATES DI D~STRICT OF MAS~=,
Page 3 and 4: (5) As of October 1989, Raymond J.
Page 5 and 6: debts. (c) The defendant FRANCIS P.
Page 7 and 8: winter Hill Gang during the 1970's.
Page 9 and 10: paragraph (k) below. THE RACKETEERI
Page 11 and 12: MANNER AND MEANS OF THE CONSPIRACY
Page 13: ookmakers as well as between bookma
Page 17 and 18: "drug dealers") were forced to asso
Page 19 and 20: (a) the defendant ROBERT P. DELUCA,
Page 21 and 22: who were engaged in unlawful activi
Page 23 and 24: threats of physical harm, property
Page 25 and 26: force, violence, and fear including
Page 27 and 28: including George Kaufman and Franci
Page 29 and 30: article in commerce in violation of
Page 31 and 32: induced by the wrongful use of actu
Page 33 and 34: Edward "wimpy" Bennett with the int
Page 35 and 36: and unlawfully conspire together an
Page 37 and 38: establishment, and carrying on of u
Page 39 and 40: Rhode Island and the Commonwealth o
Page 41 and 42: District of Massachusetts, the defe
Page 43 and 44: means to collect and attempt to col
Page 45 and 46: violence, and fear including indire
Page 47 and 48: and participate in the conduct of t
Page 49 and 50: COUNT TWO (18 USC §1962(c» 1. P
Page 51 and 52: 4. Racketeering Act 33 relating to
Page 53 and 54: usurious rate was at least twice th
Page 55 and 56: including indirect threats of physi
Page 57 and 58: COUNT FIVE (18 U.S.C. §§1951 and
Page 59 and 60: COUNT SEVEN (18 U.S.C. §§1951 and
Page 61 and 62: COUNT NINE (18 U.S.C. §§1951 and
Page 63 and 64: COUNT ELEVEN (18 U.S.C. §§1951 an
Page 65 and 66:
COUNT THIRTEEN (18 U.S.C. §§1951
Page 67 and 68:
COUNT FIFTEEN (18 U.S.C. §§1951
Page 69 and 70:
COUNT SEVENTEEN (18 USC §§1951 a
Page 71 and 72:
COUNT NINETEEN (18 USC §371) Cou
Page 73 and 74:
Hillary, and William Winn to unlawf
Page 75 and 76:
winn and Francis P. Salemme, Jr. re
Page 77 and 78:
Massachusetts to Las Vegas, Nevada
Page 79 and 80:
COUNT TWENTY-ONE (18 U.S.C. §1952)
Page 81 and 82:
COUNT TWENTY-THREE (18 U.S.C. §371
Page 83 and 84:
DELUCA were inducted as Soldiers of
Page 85 and 86:
COUNT TWENTY-FOUR (18 U.S.C. §§1
Page 87 and 88:
COUNT TWENTY-SIX (18 USC §1952) On
Page 89 and 90:
COUNT TWENTY-EIGHT (18 USC §1512)
Page 91 and 92:
RACKETEERING FORFEITURE ALLEGATIONS
Page 93:
A TRUE BILL DISTRICT OF MASSACHUSE
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