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illegal gambling activity, with his 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 thereby did obstruct, delay, and affect commerce and the movement of any article in 'commerce in violation of Title 18, united states Code, sections 1951 and 2. 34. Racketeering Act #11: From in or before the late 1980's through June 1993, in the District of Massachusetts, the defendants, JAMES J. BULGER and STEPHEN J. FLEMMI, anct other persons known and unknown to the Grand Jury, including George Kaufman, did knowingly and unlawfully obtain property, to wit, united states currency from Howard Levenson who was engaged in illegal gambling activity, with his 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 thereby did obstruct, delay, and affect commerce and the movement of any article in commerce in violation of Title 18, United states Code, sections 1951 and 2. 35. Racketeering Act #12: From in or before 1986 through in or after october 1993, in the District of Massachusetts, the defendants, JAMES J. BULGER, STEPHEN J. FLEMMI, and FRANCIS P. SALEMME, and other persons known and unknown to the Grand Jury, 26
including George Kaufman and Francis P. Salemme, Jr., did knowingly and unlawfully obtain property, to wit, united states currency from Joseph A. Yerardi, Jr. who was engaged in illegal gambling and loansharking activity, with his 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 thereby did obstruct, delay, and affect commerce and the movement of any article in commerce in violation of Title 18, United states Code, sections 1951 and 2. 36. Racketeering Act #13: Continuously between approximately September 1991 and April 1994, in the District of Massachusetts, the defendant FRANCIS P. SALEMME, and other persons known and unknown to the Grand Jury, including Francis P. Salemme, Jr., did knowingly and unlawfully obtain property, to wit, United states currency'from Peter Fiumara who was engaged in loansharking activity, with his 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 thereby did obstruct, delay, and affect commerce and the movement of any article in commerce in violation of Title 18, United states Code, sections 1951 and 2. 37. The defendant FRANCIS P. SALEMME committed the 27
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 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: force, violence, and fear including
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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