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grand jury in 1993, Yerardi fled to Florida where he was assisted by John Martorano who aided and abetted Yerardi in the conduct of Yerardi's illegal activities while Yerardi was a fugitive and who took control of these Lllegal activities after Yerardi was apprehended in April 1994. PATTERN OF RACKETEERING ACTIVITY 24. Racketeering· Act #1: From in or before January 1979, ~nd continuing until in or about June 1994, 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 did conspire with each other and with other persons known and unknown to the Grand Jury including John Martorano, George Kaufman, and Francis P. Salemme, Jr., to obtain property, to wit, united states currency, from persons known and unknown to the Grand Jury, including, but not limited to the following individuals, Burton Krantz, Edward Lewis, Thomas Ryan, Richard Brown, Mitchell Zukoff, Howard .Levenson, Joseph Yerardi, Bernard Weissman, James Katz, Michael Dezotell, Peter Fiumara, Albert Figaratto, William Lindholm, Paul Moore, William Shea, John Cherry, and Edmund Richardi, 20
who were engaged in unlawful activities, including illegal gambling, illegal money lending, and illegal narcotics trafficking, with their consent, which consent was induced by the wrongful use of actual and threatened force, violence, and fear, including indirect threats of physical harm, property damage, and economic loss and to thereby obstruct, delay, and affect commerce and the movement of any artiQle in commerce in violation of Title 18, united states Code, section 1951. 25. Racketeering Act #2: From in or about and between 1970 and 1979, in the District of Massachusetts and elsewhere, John Martorano, aided and abetted by others known and unknown to the grand jury, including the defendants JAMES J. BULGER, STEPHEN J. FLEMMI, JAMES M. MARTORANO, and Howard T. Winter, did unlawfully, wilfully, and knowingly conduct, finance, manage, supervise, direct, and own all or part of an illegal gambling business, to wit, a sports betting business, in violation of the laws of the Commonwealth of Massachusetts in which said business was conducted (Massachusetts General Laws, Chapter 271, Sections 7, 9, 16A, 17, 17A.f 20, and 22), which illegal gambling business invqlved five or more persons who conducted, financed, managed, supervised, directed, and owned all or part thereof and remained in substantially continuous operation in excess of thirty (30) days and had a gross revenue of two thousand dollars ($2,000) in a single day, in violation of Title 18, united states Code, sections 1955 and 2. 21
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 and 14: ookmakers as well as between bookma
Page 15 and 16: 14. It was part of the conspiracy t
Page 17 and 18: "drug dealers") were forced to asso
Page 19: (a) the defendant ROBERT P. DELUCA,
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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