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following acts relating to extortion, the commission of anyone
of which constitutes the commission of Racketeering Act 14.
(a) Racketeering Act #14A: continuously between
approximately June 1991 and December 1993, in the Distric,t 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 Michael Dezotell 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.
(b) Racketeering Act #14B: Continuously between
approximately November 1992 and October 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, the use of a 1992 Ford Explorer from Michael Dezotell 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
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